The Concept of Beneficial Ownership in Portugal
Journal
International; Portugal
Bulletin for International Taxation 2025 (Volume 79), No. 9/10
In 2023, two arbitration tribunals issued the first decisions discussing the concept of beneficial ownership in Portugal (cases 776/2022-T and 538/2022-T). This article examines whether these decisions are aligned with CJEU case law – in particular the Danish cases – and with the rules governing treaty interpretation under the Vienna Convention (1969).