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Beneficial Ownership in International Taxation

Beneficial Ownership in International Taxation

Author: Blazej Kuźniacki
Publisher: Edward Elgar Publishing
ISBN: 9781802206067
Published In: August 2022
Format: Hardback
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents

Details

This authoritative 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. Błażej Kuźniacki 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.

Key Features:

Guidance towards solving definitional disputes between taxpayers and tax authorities
Discussion of ground-breaking judgments in cases on beneficial ownership from various jurisdictions across the world
Comprehensive reflection of tax law in action, particularly in respect of outbound investments that trigger transborder payments of dividends, interest and royalties
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

Beneficial Ownership in International Taxation will be a crucial resource for lawyers specialising in international taxation, tax practitioners and accountants, along with officials at tax authorities and judges hearing cases in this area. It will also be useful for policy makers working on cross-border taxation, and scholars and students researching international tax law.

Błażej Kuźniacki is Assistant Professor, Amsterdam Centre for Tax Law, Faculty of Law, University of Amsterdam, the Netherlands; Research Assistant Professor, Faculty of Law and Administration, Łazarski University, Poland and Advisor, PwC Global Tax Policy, the Netherlands.

Preface

1. Introduction to Beneficial Ownership in International Taxation

2. Canons of interpretation relevant to the concept of beneficial ownership

3. The origin and evolution of the concept of BO in international tax law

4. General themes in tax jurisprudence on the concept of BO

5. International case law

6. EU case law

7. Current and future issues facing the concept of beneficial ownership

Index