The Resource The concept of beneficial owner : new developments in Mexican tax litigation

The concept of beneficial owner : new developments in Mexican tax litigation

Label
The concept of beneficial owner : new developments in Mexican tax litigation
Title
The concept of beneficial owner : new developments in Mexican tax litigation
Creator
Subject
Language
  • eng
  • eng
Summary
The high chamber of Mexico's tax court recently issued a decision confirming that the Mexican tax authorities are required to recognize a beneficial owner under a tax treaty, even if the relevant payment was made to a transparent entity in a third country. This decision is important for two reasons. First, it represents an interesting departure from the tendency of the Mexican tax court to rule in favour of the tax authorities in tax disputes involving international tax issues. Historically, the authorities have prevailed in such cases, in part due to the inherent complexity of the subject matter. Second, the decision is articulate and forward-thinking. As the ruling has been confirmed by the collegiate court, it is a final decision. This article discusses the background and facts of the case, the arguments, and the deciion, and finally makes comments
Citation source
In: Tax management international journal. - Arlington. - Vol. 42 (2013),
http://library.link/vocab/creatorName
  • González Orta, R
  • Martínez D'Meza, M
Geographic coverage
  • Latin America
  • Central America
Language note
English
http://library.link/vocab/subjectName
  • beneficial ownership
  • tax treaty
  • case law
Label
The concept of beneficial owner : new developments in Mexican tax litigation
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2013/T/TAXMAINJ/vol.42/9_553-555.zip
Publication
Note
20131101

Library Locations

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      52.3736660 4.9336932
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