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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| Format: | Article |
| Language: | English |
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Taylor & Francis Group
2025-12-01
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| Series: | Cogent Business & Management |
| Subjects: | |
| Online Access: | https://www.tandfonline.com/doi/10.1080/23311975.2024.2444549 |
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