The document summarizes a presentation on hybrid financial instruments. It defines hybrid instruments as those that have economic characteristics inconsistent with their legal form. It discusses types of hybrid instruments like convertible notes and dividend yielding bonds. It also covers the classification of hybrid instruments from tax perspectives of issuers and investors. The taxation of payments from hybrid instruments and double taxation relief is discussed. Case studies on the approaches of the UK and US to hybrid instrument taxation are provided.

1. Certificate Course on International Taxation by WIRC of ICAI Ahmedabad Branch Hybrid Financial Instruments Presented by: Mr. Paresh P. Shah P.P. Shah & Associates Chartered Accountants Email: ppshahandassociates@gmail.com 11th December 2010 P.P. Shah & Associates

27. Thank You 11th December 2010 P.P. Shah & Associates