Paul Radcliffe and Martin Walker of Citi's Europe Middle East and Africa (EMEA) Tax group suggest that beneficial ownership urgently requires a more closely defined universal tax meaning
Tax advisers are often required to apply the concept of beneficial ownership to ascertain the tax outcome of a transaction. In many commercial scenarios especially where a payment is made cross-border the correct tax treatment in the source country can be applied only once the identity of the beneficial owner is known. Yet for such a key international tax concept beneficial ownership remains a surprisingly nebulous term. This is problematic enough; more concerning is the fact that law and practice in relation to beneficial ownership vary from country to country. One country may have a well-established approach (typically common law jurisdictions)...
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Paul Radcliffe and Martin Walker of Citi's Europe Middle East and Africa (EMEA) Tax group suggest that beneficial ownership urgently requires a more closely defined universal tax meaning
Tax advisers are often required to apply the concept of beneficial ownership to ascertain the tax outcome of a transaction. In many commercial scenarios especially where a payment is made cross-border the correct tax treatment in the source country can be applied only once the identity of the beneficial owner is known. Yet for such a key international tax concept beneficial ownership remains a surprisingly nebulous term. This is problematic enough; more concerning is the fact that law and practice in relation to beneficial ownership vary from country to country. One country may have a well-established approach (typically common law jurisdictions)...
If you are not a subscriber, subscribe now to read this content.
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