Beneficial ownership in international taxation

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The item Beneficial ownership in international taxation represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
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Summary: This book provides a structural, global view of evolving judicial and doctrinal trends in the understanding of beneficial ownership in international taxation. Despite attempts by the OECD to clarify the concept, it remains ambiguous to tax authorities, courts and scholars alike, which has detrimental effects on the functioning of tax treaties. The author presents a route towards an international autonomous meaning of beneficial ownership in international taxation, while also offering a comprehensive explanation of the divergent understandings and tax policy arguments underpinning its continuing ambiguity. The book provides a guidance towards solving definitional disputes between taxpayers and tax authorities. It discusses cases on beneficial ownership from various jurisdictions across the world. In addition, it reflects on tax law in action, particularly in respect of outbound investments that trigger transborder payments of dividends, interest and royalties. The book also makes clear demarcation between appropriate and inappropriate usage of beneficial ownership by authorities and courts when addressing the issue of abuse of tax treaties and EU Directives

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Summary: This book provides a structural, global view of evolving judicial and doctrinal trends in the understanding of beneficial ownership in international taxation. Despite attempts by the OECD to clarify the concept, it remains ambiguous to tax authorities, courts and scholars alike, which has detrimental effects on the functioning of tax treaties. The author presents a route towards an international autonomous meaning of beneficial ownership in international taxation, while also offering a comprehensive explanation of the divergent understandings and tax policy arguments underpinning its continuing ambiguity. The book provides a guidance towards solving definitional disputes between taxpayers and tax authorities. It discusses cases on beneficial ownership from various jurisdictions across the world. In addition, it reflects on tax law in action, particularly in respect of outbound investments that trigger transborder payments of dividends, interest and royalties. The book also makes clear demarcation between appropriate and inappropriate usage of beneficial ownership by authorities and courts when addressing the issue of abuse of tax treaties and EU Directives