In this article, the authors examine the implications of Decision No. 17746 of 22 June 2021 of the Italian Supreme Court of Cassation regarding “beneficial ownership” and its interaction with abuse of tax treaties in the context of royalty payments, as well as the allocation of the burden of proof upon the withholding agent.

Arginelli, P., Tenore, M., Key Decision of the Italian Supreme Court on the Relationship between the Concepts of Beneficial Ownership and Abuse of Tax Treaties, <<BULLETIN FOR INTERNATIONAL TAXATION>>, 2022; 2022 (5): 261-268 [https://hdl.handle.net/10807/222946]

Key Decision of the Italian Supreme Court on the Relationship between the Concepts of Beneficial Ownership and Abuse of Tax Treaties

Arginelli, Paolo;
2022

Abstract

In this article, the authors examine the implications of Decision No. 17746 of 22 June 2021 of the Italian Supreme Court of Cassation regarding “beneficial ownership” and its interaction with abuse of tax treaties in the context of royalty payments, as well as the allocation of the burden of proof upon the withholding agent.
Inglese
Arginelli, P., Tenore, M., Key Decision of the Italian Supreme Court on the Relationship between the Concepts of Beneficial Ownership and Abuse of Tax Treaties, <<BULLETIN FOR INTERNATIONAL TAXATION>>, 2022; 2022 (5): 261-268 [https://hdl.handle.net/10807/222946]
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Utilizza questo identificativo per citare o creare un link a questo documento: https://hdl.handle.net/10807/222946
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