Beneficial ownership in international taxation / Błażej Kuźniacki.

Format:

Book

Author/Creator:

Kuźniacki, Błażej, author.

Contributor:

Edward Elgar Publishing, publisher.

Series:

Elgar Tax Law and Practice

Language:

English

Subjects (All):

International business enterprises--Taxation--Law and legislation.

International business enterprises.

Conflict of laws--Taxation.

Conflict of laws.

Double taxation.

Beneficial ownership.

Physical Description:

1 online resource (384 pages)

Place of Publication:

London, England ; Northampton, Massachusetts : Edward Elgar Publishing, [2022]

Summary:

"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"-- Provided by publisher.

Contents:

Front Matter

Copyright

CONTENTS

EXTENDED CONTENTS

PREFACE

TABLE OF CASES

TABLE OF LEGISLATION

1 INTRODUCTION TO BENEFICIAL OWNERSHIP IN INTERNATIONAL TAXATION

2 CANONS OF INTERPRETATION RELEVANT TO THE CONCEPT OF BENEFICIAL OWNERSHIP (BO)

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 BO

INDEX.

Notes:

Includes bibliographical references and index.

Description based on print version record.

Other Format:

Print version: Kuźniacki, Błażej Beneficial Ownership in International Taxation

ISBN:

9781802206074