When does burden of proof lie with tax authority?
The tax authorities often put taxpayers in the position of having to prove the overall accuracy
Italian Supreme Court applying beneficial ownership and abuse of right
In its July judgement, the Italian Supreme Court applied the principles formulated by the Court of Justice of the EU (CJEU)…
Guidance on determining beneficial ownership: part two
The Court of Justice of the EU issued judgments in a number of…
Regional court: tax exempt sale of shares financed by a tax exempt dividend is abuse of right
The Regional Court in Brno recently dealt with the sale of shares by individuals – natural persons financed by a tax-exempt dividend payment, concluding that the case involved an abuse …
Guidance on determining beneficial ownership
The Advocate General has recently presented her views on a number of cases pending before the Court of Justice