With the rapid development of financial transactions and innovative financial products in China, hybrid investments, which normally have a dual nature of equity and debt investments, have become a popular investment vehicle used by many companies, such as trust companies, in recent years. Examples of such hybrid investments include preferred stocks and convertible bonds from which periodic fixed interests or profits would be derived.
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems