Beneficial Ownership: Concept, History and Perspective

Journal
Poiret, C.
International
European Taxation 2016 (Volume 56), No. 7
FormatPDF
EUR
40
| USD
45
(VAT excl.)

This article traces the evolution of the beneficial ownership concept, both internationally and within the European Union, in the context of two decisions of the Swiss Supreme Court handed down in May 2015, wherein it was held that two Danish banks, involved in derivative transactions, should be denied a withholding tax refund, as they are not the beneficial owners.