The concept of beneficial ownership is frequently called one of the most decisive questions in international tax law. Despite this fact, neither scholars nor courts have found a generally accepted definition. This book provides a comprehensive overview of the latest developments concerning the concept of beneficial ownership. Highly renowned tax experts both from academia and practice analyse the most important decisions recently made by courts around the world. Moreover, the recently published OECD Discussion Draft on the meaning of beneficial ownership is being taken into account and the meaning of the term qbeneficial ownerq used in European tax law in comparison to its meaning in tax treaty law is being assessed. The authors not only draw a better picture of the status quo but also enhance the discussion of the future meaning of the term qbeneficial ownerq.This uncertainty led HM Revenue aamp; Customs to issue some draft guidance which eventually became paragraphs in the HMRC International Tax Manual. These paragraphs are sufficiently interesting to merit quotation in full: INTM332050anbsp;...
|Title||:||Beneficial Ownership: Recent Trends|
|Author||:||Michael Lang, Pasquale Pistone, Josef Schuch, Claus Staringer and Alfred Storck|
|Publisher||:||IBFD - 2013|