Beneficial ownership

The U.S. has a highly successful international financial service industry that is important to the U.S. economy, exemplified by, firstly, the international financial centers such as Miami and New…

On 10 July 2020, the Italian Supreme Court (also ‘Court’) issued its decision No. 14756 (‘Decision 14756/2020’, published in H&I 2020/470 with comments by Arginelli and Tenore) dealing, amongst…

With the General’s Court ruling on July 15, 2020, a first step has been taken in the question whether the Irish government has provided Apple with State Aid. So far, the General Court has ruled that…

Recently, national courts of several EU member States (notably France[1], Italy[2], the Netherlands[3] and Spain[4]) referred to the landmark judgments of the Court of Justice of the European Union (…

In its judgment of January 21, 2020 (Santander case, available here), the European Court of Justice (ECJ) not only prevented the Spanish Central Tax Tribunal (Tribunal Económico-Administrativo…

With a judgment rendered on 16 December 2019 (case no. 2C_209/2017), the Swiss Federal Supreme Court (“FSC”) rejected several reclaims of Swiss dividend withholding taxes made by a Luxembourg…

It is widely accepted that the United States of America is one of the most litigious countries on earth. As of 2010, US residents spent about 2.2% of their GDP (approximately 310 Billion Dollars)…

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…

The judgements of the CJEU in N Luxembourg 1 v Skatteministeriet (Case C-115/16) and joined cases and in T Danmark (Case C-116/16)  and another joined case, on 26 February 2019, once again addressed…