Beneficial ownership: is it about blocking tax avoidance, or is it all about income attribution?
2024 11 11
Recent cases and trends in beneficial ownership and treaty eligibility were some of the key topics at The New Era of Taxation conference, hosted by the International Bar Association’s Taxes Committee. WALLESS Partner Dr Aistė Medelienė joined a panel of tax experts to discuss these issues and their impact on global tax practices.
Here are Aistė’s key takeaways:
- The purpose of the beneficial ownership rule remains under debate: is it aimed at combating tax avoidance and treaty shopping, or is it primarily a framework for income attribution?
- Globally, tax authorities often prioritize domestic rules (GAAR or SAAR) over double tax treaties, highlighting a lack of consistency that could shape future tax policy.
- Bonus insight: the market is eagerly awaiting an update from the The Court of Justice of the European Union, as clarity is needed following the uncertainties raised by the Danish cases.
As tax policies and global practices change, WALLESS is glad to take part in creating a more connected international tax landscape.