Beneficial owner: do direito tributário internacional ao civil law
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2011-11
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Mello, Linneu de Albuquerque
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This paper is proposed to analyze the Beneficial Owner concept, considering national and international doctrines, some of the most important cases regarding the mentioned concept, and comparing its applicability within common law and civil law countries. Therefore, it is intended to: conceptualize the Beneficial Owner institute; indicate the problems involved in such concept; demonstrate the importance of its understanding; analyze the main international cases regarding the applicability of the Beneficial Owner concept; the difference of applying the mentioned concept within common law and civil law countries, as well as analyze its enforcement when the international tax treaty does not have an beneficial ownership clause.