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After a chaotic process marked by the no-confidence vote of the Government formed by the French Prime Minister Barnier in December 2024...
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In Hargreaves Property Holdings Limited v HMRC, the Court of Appeal dismissed the taxpayer’s appeal against the Upper Tribunal’s decision...
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Across a number of European jurisdictions, relief from withholding tax may be denied where the recipient of a dividend, interest or...
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The Italian tax authorities continue to challenge interposed conduit entities using the beneficial ownership test to deny withholding tax...
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Increasingly, the French tax authorities are making use of the beneficial ownership concept to deny withholding tax exemptions (or the...
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In the Netherlands, the term beneficial owner can arguably have two different meanings: a domestic law meaning and a tax treaty law...
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In practice, the beneficial ownership test is most often applied in connection with dividend withholding taxes but may also be relevant...
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Beneficial ownership (or beneficial entitlement) concepts are used across the UK tax code in relation to domestic provisions as well as...
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The Portuguese tax authority has started to deny withholding tax refunds (requested by non-resident recipients who had not yet completed...
Since the Danish conduit cases, the Spanish tax authorities have used the beneficial ownership concept to deny the application of...
The Upper Tribunal’s decision is a helpful ‘back-to-basics’ on the nature and purpose of the provisions on withholding tax on interest...
Italian Supreme Court Decision No. 3380 of 3 February deals with the interpretation of the beneficial owner (BO) requirement under the...
The Peruvian Tax Court (Tribunal Fiscal) denied the application of the favourable withholding tax rate provided for in Article 12...
The Court declined to disapply the reduced royalties withholding tax rate under the Spain-Switzerland Tax Treaty on the basis that the...
The 2019 Colombian tax reform introduced a new definition of beneficial owner for tax purposes. But the result may be an increase in...
When we were still immersed in uncertainty following the judgments of the CJEU on the Danish conduit cases, the Spanish High Tax Court...