This topic relates mainly to cross-border mergers and acquisitions because it is generally, but not always, upon mergers and acquisitions that stapled stock and dividend access shares are implemented, in order to enable the shareholders in the target company to retain after the merger some of the tax benefits which were associated with their prior shareholding.

This topic also relates to non-discrimination because most of the tax systems have different tax treatments for foreign shares and domestic shares, both with respect to capital taxation and dividend income taxation.