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In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...
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There are numerous specific anti-avoidance provisions (SAARs) and the general anti-abuse rule (GAAR), and the Italian tax authorities may...
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There are multiple purpose tests across different parts of the French corporate income tax legislation pursuant to which the French tax...
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Within the Netherlands, there are various anti-abuse or anti-avoidance rules containing purpose tests. Most relevant within the context...
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Germany has a general anti-abuse rule (GAAR) as well as other purpose tests under various specific anti-abuse rules (SAARs) in different...
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In addition to the general anti-abuse rule (GAAR), numerous purpose tests are built into the UK tax code. Every time a new set of tax...
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There are multiple purpose test provisions pursuant to which the Portuguese tax authorities can recharacterise or disregard a transaction...
The Spanish tax authorities can challenge transactions under purposes tests in the two different general anti-abuse rules (GAARs) as well...
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Last week, HM Treasury released its Summary of Responses document to the consultation published earlier this year seeking views on the...
Across a number of European jurisdictions, relief from withholding tax may be denied where the recipient of a dividend, interest or...
The Italian tax authorities continue to challenge interposed conduit entities using the beneficial ownership test to deny withholding tax...
Increasingly, the French tax authorities are making use of the beneficial ownership concept to deny withholding tax exemptions (or the...
In the Netherlands, the term beneficial owner can arguably have two different meanings: a domestic law meaning and a tax treaty law...
In practice, the beneficial ownership test is most often applied in connection with dividend withholding taxes but may also be relevant...
Beneficial ownership (or beneficial entitlement) concepts are used across the UK tax code in relation to domestic provisions as well as...
The Portuguese tax authority has started to deny withholding tax refunds (requested by non-resident recipients who had not yet completed...