Advocate General interprets ‘beneficial ownership’ under EU directives, independent of OECD MTC

Mar 12,2018

In connection with a tax dispute in Denmark, the Advocate General proposes to the EU Court of Justice that the concept of ‘beneficial ownership’ must be interpreted under EU law autonomously and independently of the commentaries on the OECD Model Tax Convention (‘MTC’), remarks that OECD MTCs are not legally binding, multilateral conventions, but only unilateral recommendations to member countries; Danish Tax Authority had claimed that interest paymen...


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