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?
Resource Information
The item Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength? represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength? represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- 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
- Language
- eng
- 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?
- 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?
- Label
- Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength?
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Beneficial-ownership-interpreted-to-what-extent/E8G1uccIeHc/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Beneficial-ownership-interpreted-to-what-extent/E8G1uccIeHc/">Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength?</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Beneficial-ownership-interpreted-to-what-extent/E8G1uccIeHc/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Beneficial-ownership-interpreted-to-what-extent/E8G1uccIeHc/">Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength?</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
