Beneficial Ownership and Tax Treaties: A French View

Journal
Gouthière, B.
France
Bulletin for International Taxation 2011 (Volume 65), No. 4/5
PriceUSD 45

In this article, the author considers the nature and implications of the concept of beneficial ownership contained in French tax treaties and discusses whether or not, in light of the case law, it may apply independently from the domestic concept of abuse of law.