[PDF] Ship Financing And Taxation Part 2 eBook

Author : Orestis Schinas
Publisher : Springer
Page : 395 pages
File Size : 49,2 MB
Release : 2014-11-19
Category : Law
ISBN : 3662434105

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This book is a major work that focuses exclusively on ship finance and includes contributions on the increasingly complex field of ship finance, which has over the last two decades become a key aspect in the world of shipping and ship owning. The book offers an enlightening mix of theoretical analysis and well-founded practical insights into the daily markets. Given that ship finance continues to develop dynamically around the world, the book covers subjects ranging from the German KG market to Islamic Finance, from loans to legal aspects and from asset pricing to risk management.

Author : Jakob Bundgaard
Publisher : Kluwer Law International B.V.
Page : 498 pages
File Size : 43,67 MB
Release : 2016-11-15
Category : Law
ISBN : 9041183183

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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. Focusing on hybrid financial instruments (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 – this book analyses their treatment under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered. Advocating for a broader scope of application of HFIs as part of the financing of companies in Europe alongside traditional sources of debt and equity financing, the book addresses such issues and topics as the following: • problems associated with the debt-equity distinction in international tax law; • cross-border tax arbitrage and linking rules; • drivers behind the use and design of HFIs; • tax law impact of perpetual and super maturity debt instruments, profit participating loans, convertible bonds, mandatory convertible bonds, contingent convertibles, preference shares and warrant loans on HFIs; • financial accounting treatment; • administrative guidance; • influence of the TFEU on Member States’ approaches to classification of HFIs; • interpretation of the Parent-Subsidiary Directive by the European Court of Justice; • applicability of the OECD Model Tax Convention; and • implications of the OECD Base Erosion and Profit Shifting (BEPS) project. Throughout this book, the analysis draws upon preparatory works, case law, and legal theory in English, German, and the Scandinavian languages. In conclusion, the author considers tax policy issues, and identifies and outlines possible high-level solutions. Actual or potential users of HFIs will greatly appreciate the clarity and insight offered here into the capacity and tax implications of HFIs. The book not only examines whether existing legislation is sufficient to handle the issues raised by international HFIs, but also provides an in-depth analysis of the interaction between corporate financing and tax law in the light of today’s financial innovation. Corporate executives and their counsel will find it indispensable in the international taxation landscape that is currently coming into view, and academics and policymakers will hugely augment their understanding of a complex and constantly changing area of tax law.

Author : Vincent Gabrielsen
Publisher : JHU Press
Page : 330 pages
File Size : 14,67 MB
Release : 2010-11-01
Category : History
ISBN : 0801899303

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To meet the enormous expenses of maintaining its powerful navy, democratic Athens gave wealthy citizens responsibility for financing and commanding the fleet. Known as trierarchs—literally, ship commanders—they bore the expenses of maintaining and repairing the ships, as well as recruiting and provisioning their crews. The trierarchy grew into a powerful social institution that was indispensable to Athens and primarily responsible for the city's naval prowess in the classical period. Financing the Athenian Fleet is the first full-length study of the financial, logistical, and social organization of the Athenian navy. Using a rich variety of sources, particularly the enormous body of inscriptions that served as naval records, Vincent Gabrielsen examines the development and function of the Athenian trierarchy and revises our understanding of the social, political, and ideological mechanisms of which that institution was a part. Exploring the workings, ships, and gear of Athens' navy, Gabrielsen explains how a huge, costly, and highly effective operation was run thanks to the voluntary service and contributions of the wealthy trierarchs. He concludes with a discussion of the broader implications of the relationship between Athens' democracy and its wealthiest citizens.

Author : American Bar Association. House of Delegates
Publisher : American Bar Association
Page : 216 pages
File Size : 37,53 MB
Release : 2007
Category : Law
ISBN : 9781590318737

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The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.

Author : Gianluigi Bizioli
Publisher : Kluwer Law International
Page : 280 pages
File Size : 30,13 MB
Release : 2020-02-07
Category :
ISBN : 9789403511702

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The EU's Anti-Tax Avoidance Directive (ATAD), implemented in January 2019, confronts Member States with complex challenges, particularly via the introduction of an interest limitation rule. This timely book, the first in-depth analysis of the features and implications of the directive, provides insightful and practical discussions by experts from around Europe on the crucial interactions of the ATAD with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms. Specific issues and topics covered include the following: relation with the OECD's Base Erosion and Profit Sharing project (BEPS) and the EU's Common Corporate Tax Base initiative; technical subjects relating to corporate taxation and debt funding; problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies; exclusion clauses for interest expenses; and interplay between interest limitation rules and anti-hybrid rules. A comparative analysis of implementation issues in four leading Member States--Germany, Italy, Spain and The Netherlands--as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated to the implementation of the ATAD. This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States.