TAX ADMINISTRATION OF HYBRID FINANCIAL INSTRUMENTS: SPECIFICITY AND EVALUATION OF ITS NECESSITY
The purpose of this article is to determine whether there is a justified need for a special methodological approach to tax administration of hybrid financial instruments. Nowadays a lot of countries introduce special corporate income tax rules to tax hybrid financial instruments, following to a significant extent recommendations of Organization for Economic Cooperation and Development (OECD). However, OECD does not recommend a special approach to tax administration of hybrid financial instruments, which leads to a question what should such approach look like? Should it have special characteristics? Author concludes that specificity of tax administration of hybrid financial instruments is needed and its application is useful. Such a conclusion is caused by the nature of hybrid financial instruments: their cross-border hybrid nature does not allow tax authorities to control systematically absence of international double non-taxation by means of instruments generally applied to other tax objects.