The Resource Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength?

Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength?

Label
Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength?
Title
Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength?
Creator
Subject
Language
eng
Summary
The interpretation of the concept of 'beneficial ownership' in the field of cross-border taxation is the subject of dispute among the international community. From 1977 onwards, a major question is how beneficial ownership should be defined for tax treaty purposes. After the concept of beneficial ownership was included in the EU's Interest and Royalties Directives, the same question arose for the interpretation of the concept from an EU perspective. The authors examine both the OECD and EU concepts separately from a historical and teleological perspective and attempt to find common grounds for interpretation, especially after the European Court of Justice judgment in the Danish cases. They conclude their research by suggesting potential ways forward for a better alignment of the OECD's and EU's interpretation of the beneficial ownership concept
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 49 (2021), no. 3 ; p. 254-277
http://library.link/vocab/creatorName
  • Hamra, C
  • Korving, J.J.A.M
Language note
English
http://library.link/vocab/subjectName
  • European Union
  • OECD
  • beneficial ownership
  • Interest and Royalties Directive
  • tax treaty
  • treaty interpretation
  • interest
  • dividend
  • royalties
  • ECJ case law
Label
Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength?
Instantiates
Publication
Label
Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength?
Publication

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