Key Decision of the Italian Supreme Court on the Relationship between the Concepts of Beneficial Ownership and Abuse of Tax Treaties

Paolo Arginelli; Mario Tenore

Key Decision of the Italian Supreme Court on the Relationship between the Concepts of Beneficial Ownership and Abuse of Tax Treaties

Paolo Arginelli, Mario Tenore

Università Cattolica del Sacro Cuore

Research output: Contribution to journal › Article › peer-review

Abstract

In this article, the authors examine the implications of Decision No. 17746 of 22 June 2021 of the Italian Supreme Court of Cassation regarding “beneficial ownership” and its interaction with abuse of tax treaties in the context of royalty payments, as well as the allocation of the burden of proof upon the withholding agent.

Original language	English
Pages (from-to)	261-268
Number of pages	8
Journal	Bulletin for International Taxation
Volume	2022
Publication status	Published - 2022

Keywords

Abuse of tax treaties
Beneficial ownership
Royalties

Cite this

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title = "Key Decision of the Italian Supreme Court on the Relationship between the Concepts of Beneficial Ownership and Abuse of Tax Treaties",

abstract = "In this article, the authors examine the implications of Decision No. 17746 of 22 June 2021 of the Italian Supreme Court of Cassation regarding “beneficial ownership” and its interaction with abuse of tax treaties in the context of royalty payments, as well as the allocation of the burden of proof upon the withholding agent.",

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AB - In this article, the authors examine the implications of Decision No. 17746 of 22 June 2021 of the Italian Supreme Court of Cassation regarding “beneficial ownership” and its interaction with abuse of tax treaties in the context of royalty payments, as well as the allocation of the burden of proof upon the withholding agent.

KW - Abuse of tax treaties

KW - Beneficial ownership

KW - Royalties

KW - Abuse of tax treaties

KW - Beneficial ownership

KW - Royalties

UR - http://hdl.handle.net/10807/222946

M3 - Article

SN - 1819-5490

VL - 2022

SP - 261

EP - 268

JO - Bulletin for International Taxation

JF - Bulletin for International Taxation

ER -

Key Decision of the Italian Supreme Court on the Relationship between the Concepts of Beneficial Ownership and Abuse of Tax Treaties

Abstract

Keywords

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