Efficiency of CFC taxation concerning hybrid instruments – a comparative analysis of Spain, Germany, and Austria

The objective of this study is to show that an indirect interest in a controlled foreign corporation (CFC) through hybrid participation instruments may not be subject to CFC taxation. This is the case where the taxpayer holds a hybrid participation instrument in a foreign intermediary company (equit...

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Bibliographic Details
Main Author: Thomas Kollruss
Format: Article
Language:English
Published: Taylor & Francis Group 2025-12-01
Series:Cogent Business & Management
Subjects:
Online Access:https://www.tandfonline.com/doi/10.1080/23311975.2024.2444549
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