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

Arginelli Paolo; Tenore Mario

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

Arginelli Paolo, Tenore Mario

Pirola Pennuto Zei & Associati

Risultato della ricerca: Contributo in rivista › Articolo › 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.

Lingua originale	Inglese
pagine (da-a)	261-268
Numero di pagine	8
Rivista	Bulletin for International Taxation
Volume	2022
Numero di pubblicazione	5
Stato di pubblicazione	Pubblicato - 2022
Pubblicato esternamente	Sì

All Science Journal Classification (ASJC) codes

Legge
Contabilità
Finanza
Economia ed Econometria

Keywords

Abuse of tax treaties
Beneficial ownership
Royalties

Altri file e collegamenti

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

Abstract

All Science Journal Classification (ASJC) codes

Keywords

Altri file e collegamenti

Fingerprint

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