International - Beneficial Ownership: Concept, History and Perspective
- C. Poiret
- European Taxation, 2016 (Volume 56), No 7
- 16 June 2016
This article traces the evolution of the beneficial ownership concept, both internationally and within the European Union, in the context of two decisions of the Swiss Supreme Court handed down in May 2015, wherein it was held that two Danish banks, involved in derivative transactions, should be denied a withholding tax refund, as they are not the beneficial owners.