by VDT Attorneys | Sep 17, 2025 | Corporate advisors, Corporate structuring, Hybrid equity instrument, Income Tax Act, International Tax Law, Preference shares
Hybrid equity instruments aim to prevent the use of financial instruments masquerading as equity when they have debt-like characteristics. Dividends received by qualifying hybrid equity instruments would then be reclassified as income. The current anti-avoidance...
by VDT Attorneys | Sep 1, 2025 | Corporate structuring, Income Tax Act, International Tax Law, Preference shares
Current anti-avoidance rules under section 8EWhere instruments have the characteristics of debt but are structured as equity, the anti-avoidance provisions embodied in section 8E of the ITA become applicable. The taxing event envisaged by section 8E of the ITA is that...
by VDT Attorneys | Jul 23, 2024 | Income Tax, Income Tax Act, Tax, Tax Advisory
Section 24O of the ITA can in certain circumstances be utilised in acquisition transactions when a company obtains financing to acquire equity shares in another company. The operative provision of this section essentially permits the interest levied on the financing...
