Beneficial Ownership in International Taxation

This book provides a structural, global view of evolving judicial and doctrinal trends in the understanding of beneficial ownership in international taxation, which remains ambiguous to tax authorities, courts, and scholars alike. Błażej Kuźniacki offers a route towards an international autonomous meaning of beneficial ownership and discusses the divergent understandings and tax policy arguments underpinning its continuing ambiguity. It is a crucial resource for lawyers, tax practitioners, accountants, officials at tax authorities, and judges hearing cases in this area, as well as policy makers and scholars researching international tax law.

Format: Hardback
Length: 384 pages
Publication date: 12 August 2022
Publisher: Edward Elgar Publishing Ltd

This comprehensive book offers a structural and global perspective on the evolving judicial and doctrinal trends in understanding beneficial ownership in international taxation. Despite the OECD's efforts to clarify the concept, it remains ambiguous to tax authorities, courts, and scholars, which has detrimental effects on the functioning of tax treaties. Błażej Kuźniacki presents a pathway towards an international autonomous meaning of beneficial ownership in international taxation, while also providing a comprehensive explanation of the divergent understandings and tax policy arguments underpinning its continued ambiguity.

Key Features:
Guidance towards resolving definitional disputes between taxpayers and tax authorities
Discussion of groundbreaking 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, accountants, tax authority officials, 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.

Dimension: 244 x 169 (mm)
ISBN-13: 9781802206067