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Beneficial Ownership in International Taxation. 国際課税における受益的所有権
・ISBN 978-1-80220-606-7 hard GB£ 184.00
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| 著者・編者 | Kuzniacki, Blazej, |
|---|---|
| シリーズ | Elgar Tax Law and Practice |
| 出版社 | (E. Elgar, UK) |
| 出版年月 | 2022.08 |
| ページ数 | 432 pp. |
| 言語 | ENG |
| ニュース番号 | ＜674-705＞ |
解説
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. Blazej Kuzniacki 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.
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.
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.