Tax administration of hybrid financial instruments

Ayrapetyan Levon Kamoevich

The purpose of this article is to determine specialties of tax administration of hybrid financial instruments. Due to their cross-border hybrid nature hybrid financial instruments require special approach to control by tax authorities. From theoretical point of view it is important to understand, whether tax administration of hybrid financial instruments should comply with some special principle that is not typical for administration of any other tax object. If yes, what such principle should be about? Other important question is how a set of tax administration tools should be composed and in what order used to fit mostly the economic substance of hybrid financial instruments. Author suggests special principle of segmented approach to tax control of transactions with financial instruments and, in compliance with it, outlines target set of tax administration tools and algorithm of their application to hybrid financial instruments.

Keywords:hybrid financial instruments, tax administration, tax administration principles, international exchange of information