Part 1 of the article Convertible Debt Instruments in International Law

This two-part article contains an in-depth analysis of a variety of convertible debt instruments from the perspective of international tax law. Part 1 covers optional convertible instruments, mandatory and reverse convertibles, contingent convertibles, warrants and option loans and provides an overview of domestic law in a number of countries.

Read the article here

New book on Hybrid Financial Instruments in International Tax Law

The book examines the tax issues affecting the use of hybrid financial instruments (HFIs).

Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity.

This book analyzes the treatment of HFIs – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered.

 

The book is available here.

 

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New profiles at CORIT Advisory

CORIT Advisory proudly welcomes Karin Skov Nilausen, as senior counsel as of 1 September 2016. Karin holds a law degree and a Ph.D. degree within tax law.

 

Karin has obtained extensive experience working as a lawyer, tax consultant, tax director and tax official for more than 20 years and is widely considered a capacity within a number of important and complex areas of tax law. Her areas of expertise include international tax, EU law, transfer pricing and dispute resolution. She has i.a. taken part in the negotiations regarding the TP related BEPS reports and have handled large transfer pricing cases.

 

Karin will continue her activities within these areas and contribute to the continuing growth and success of CORIT.

 

Moreover, Karin has been lecturing on tax law for numerous years and has authored a number of articles and books on the above topics.

 

 

CORIT Advisory also proudly welcomes Louise Fjord Kjærsgaard as an associate as of 1 September 2016. Louise holds a master degree in commercial law and business administration. Louise is specializing in international tax, corporate tax and the tax consequences of the digital economy.

 

We consider the advent of Karin Skov Nilausen and Louise Fjord Kjærsgaard to be a perfect match and foresee great results from our cooperation.

 

 

About CORIT Advisory P/S

CORIT Advisory is a highly specialized and fully independent tax boutique firm, offering tax consulting services within a range of complex areas of tax law. Our primary task is to assist businesses in identifying, addressing and mitigating tax risk in a rapidly changing environment.

 

Our ambition is to be recognized as a leading knowledge provider and business partner within the international tax consulting industry. Technical competences are highly prioritized.

 

We offer a unique combination of practical and applicable tax advisory services with the knowledge and insight of academia. This unique mix is the very core of CORIT advisory and is the common denominator of the people behind the firm.