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.Commissioner of Internal Revenue, 54 for example, where a Bahamian company loaned funds to a US subsidiary and assigned the debt to a Honduran ... Northern Indiana Public Service Company v. ... Commissioner, 107 T.C. 161 ( 1996) (aSDI Netherlandsa). by the OECD, which would apply only when the obligation.
|Title||:||Beneficial Ownership: Recent Trends|
|Author||:||Michael Lang, Pasquale Pistone, Josef Schuch, Claus Staringer and Alfred Storck|
|Publisher||:||IBFD - 2013|