000			01658nab a2200241 c 4500
999			_c143885 _d143885
003			ES-MaIEF
005			20210414183100.0
007			ta
008			210414t2021 sp ||||| |||| 00| 0|spa d
040			_aES-MaIEF _bspa _cES-MaIEF
100	1		_968868 _aHamra, C.
245		0	_a Beneficial ownership interpreted, to what extent are the OECD and the EU on the same wavelength? _c C. Hamra & J.J.A.M. Korving
260			_c2021
500			_aResumen.
520			_aThe interpretation of the concept of 'beneficial ownership' in the field of cross-border taxation is the subject of dispute among the international community. From 1977 onwards, a major question is how beneficial ownership should be defined for tax treaty purposes. After the concept of beneficial ownership was included in the EU's Interest and Royalties Directives, the same question arose for the interpretation of the concept from an EU perspective. The authors examine both the OECD and EU concepts separately from a historical and teleological perspective and attempt to find common grounds for interpretation, especially after the European Court of Justice judgment in the Danish cases. They conclude their research by suggesting potential ways forward for a better alignment of the OECD's and EU's interpretation of the beneficial ownership concept.
650		4	_959746 _aBENEFICIARIO EFECTIVO
650		4	_944303 _aFISCALIDAD INTERNACIONAL
650		4	_948608 _aTRATADOS INTERNACIONALES
650		4	_941141 _aCONVENIOS
700			_952128 _aKorving, Jasper
773	0		_9164647 _oOP 2141/2021/3 _tIntertax _w(IEF)55619 _x 0165-2826 _gv. 49, n. 3, March 2021, p. 254-277
942			_cART