Taxation of hybrid instruments : Germany

A company's finance choices may generally be separated into two categories, namely equity and debt. Some instruments, however, contain both equity and debt elements and are not so easily categorized. Furthermore, the tax rules may not be consistent with straight equity or debt instruments and may differ with regard to corporate and individual tax treatment. This article is part of a comparative survey providing a guidance as to the treatment of proceeds from these instruments in Germany, Norway and USA.