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Hardcover
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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.
Industry Reviews
'There has been a need for some time for a book that provided a thorough analysis of the historical origins, changes in interpretation, and application in practice of the "beneficial ownership" concept. Professor Blazej Kuzniacki has now completely satisfied that need with a comprehensive and illuminating discussion of the BO concept. This book traces the lack of clarity over the concept from its first appearance in tax treaties through to the latest case law and its inter-relationship to post-BEPS anti-avoidance measures. Aside from its full analysis, the book adds an appendix analysing several of the leading cases on the topic. How amazing, though, that just two words in tax treaties can spawn an academic work of over 400 pages! This book should sit on the bookshelf alongside Arvid Skaar's magnum opus on "permanent establishment", where two words generated a work of over 900 pages.' -- Philip Baker QC, Gray's Inn and Oxford University, UK
'In his book on Beneficial Ownership in International Taxation Professor Kuzniacki provides for a comprehensive, profound and thought-provoking analysis of beneficial ownership as the theme has developed in the past 80 years. His work is thorough and detailed and a must-read for practitioners and academics working in international taxation.' -- Stef van Weeghel, University of Amsterdam, the Netherlands
'This is a terrific and eminently useful volume. Like "arm's-length" and "direct or indirect," "beneficial ownership" is one of those tax terms that bristles with ambiguity. Professor Kuzniacki has meticulously researched and analyzed the beneficial ownership "conundrum," thereby making a major contribution to the international tax field.' -- H. David Rosenbloom, New York University School of Law, US
ISBN: 9781802206067
ISBN-10: 180220606X
Series: Elgar Tax Law and Practice series
Published: 12th August 2022
Format: Hardcover
Language: English
Number of Pages: 384
Audience: Professional and Scholarly
Publisher: Edward Elgar Publishing Ltd
Country of Publication: GB
Dimensions (cm): 24.4 x 16.9 x 2.54
Weight (kg): 0.75
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You Can Find This Book In
This product is categorised by
- Non-FictionLawLaws of Specific JurisdictionsCompany LawBusiness Law
- Non-FictionLawLaws of Specific JurisdictionsTaxation & Duties LawPersonal Tax
- Non-FictionLawLaws of Specific JurisdictionsTaxation & Duties LawCorporate Tax
- Non-FictionAccounting & FinanceFinancePublic Accounting in FinanceTax & Taxation