The Resource Beneficial ownership : current trends

Beneficial ownership : current trends

Label
Beneficial ownership : current trends
Title
Beneficial ownership : current trends
Creator
Subject
Language
eng
Summary
This article critically studies case law on beneficial ownership in Spain, Switzerland, England, Canada and France to conclude that what seems to be the prevailing opinion (economic/substance-over-form analysis) of that term is not the one that best conforms the object and purpose of tax treaties. The minority opinion, represented by the Canadian Prévost judgements, is given attention as the most promising way to avoid some of the problems of the concept of beneficial ownership. Recent initiatives of international organizations (OECD, UN) affecting the concept of beneficial ownership are also considered to study other relevant issues in connection with beneficial ownership (liability of withholding agents when it is found that the person receiving income is not the beneficial owner, extension of the concept to other treaty articles) where clarification is needed
Citation source
In: World tax journal. - Amsterdam. - Vol. 2 (2010),
http://library.link/vocab/creatorName
Martín Jiménez, A.J
Language note
English
http://library.link/vocab/subjectName
  • beneficial ownership
  • case law
Label
Beneficial ownership : current trends
Publication

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    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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