ECONOMIC FEATURES OF HYBRID FINANCIAL INSTRUMENTS IN THE CONTEXT OF THEIR TAX ADMINISTRATION

Abstract: the purpose of this article is to determine specific economic features of hybrid financial instruments as objects of tax administration. Modern scientific and practical tax literature mainly consider issues of taxation of hybrid financial instruments while topic of their tax administration receives notably less attention. With that, development of trending methodological approach to tax administration of hybrid financial instruments requires understanding of their economic specificities, which allows to select most applicable instruments of tax administration and approach to their application. Author determined typical for hybrid financial instruments combination of debt and equity attributes within one financial instrument. It was determined that exact combination of attributes varies depending on whether agreement is legally construed as debt or equity instrument. Author suggests taking into account necessity to differentiate arrangements for the use of particular instruments of tax administration taking into account determined specialties when developing methodological approach to tax administration of hybrid financial instruments.

Keywords: hybrid financial instruments, debt obligations, equity investments, debt, equity, tax administration

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