Abuse of law, Beneficial ownership, Double Taxation, EU/EEA, International Tax Law, OECD, Substance, Tax Avoidance, Tax Treaties
Three Observations on the Danish Beneficial Ownership Cases
Jonathan Schwarz has already briefly discussed the CJEU’s judgment in the “Danish Beneficial Ownership Cases” (C-115/16, C-118/16, C-119/16, C-299/16 and C-116/16 and C-117/16), noting that the cases “represent a landmark on beneficial ownership” and comparing them to recent international tax law jurisprudence, concluding that the “voyage of discovery is certainly not at and end”. In…