The Resource The notions of "beneficial ownership"and "place of effective management" in respect of a passive holding company

The notions of "beneficial ownership"and "place of effective management" in respect of a passive holding company

Label
The notions of "beneficial ownership"and "place of effective management" in respect of a passive holding company
Title
The notions of "beneficial ownership"and "place of effective management" in respect of a passive holding company
Creator
Subject
Language
eng
Summary
In this note, the author considers a decision of the Italian Supreme Court on "beneficial ownership" and "place of effective management" for tax treaty purposes, wherein it was held that the meaning of these terms is to be determined in light of the nature and object of a financial holding company and that, therefore, a lack of substantial economic activity does not mean per se that such a company cannot be effectively established in the other contracting state
Citation source
In: European taxation. - Amsterdam. - Vol. 57 (2017), no. 6 ; p. 253-257
http://library.link/vocab/creatorName
Beretta, G
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • beneficial ownership
  • place of effective management
  • holding company
  • tax treaty
  • case law
Label
The notions of "beneficial ownership"and "place of effective management" in respect of a passive holding company
Instantiates
Publication
Label
The notions of "beneficial ownership"and "place of effective management" in respect of a passive holding company
Publication

Library Locations

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      52.37366609999999 4.9336932
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