WebJan 3, 2024 · The two judgments issued by the European Court of Justice (ECJ) on February 26, 2024 (the so-called “Beneficial Ownership Cases” or “Danish Cases”) marked a clear turning point in the application of domestic withholding tax exemptions to interest, royalties and dividends paid by EU taxpayers. WebOn 26 February 2024, the Court of Justice of the European Union (CJEU) rendered a ground-breaking decision on tax avoidance and beneficial ownership in the so-called …
New BO factsheet: Impact of the Danish beneficial ownership cases …
WebJan 12, 2024 · The focal point in the "Danish Cases" is the "beneficial owner" quality of EU resident companies receiving dividend or interest payments or accruals from their Danish resident group companies, and whether the Danish companies should have withheld tax on such payments and acted negligently in not withholding. WebFollowing the ECJ Danish Beneficial Ownership cases, Belgian Tax Authorities have been reviewing cross-border payments of ‘passive income’ including interest, dividends and royalties. EY will discuss the recent trends in this respect, the relevant elements considered regarding the reviewed investment structures and the type of corrections ... flashforge finder power supply
Danish High Court issues rulings on beneficial ownership
WebJul 17, 2024 · Executive summary. Italy’s Supreme Court (the Court), in decision n. 14756 of 10 July 2024, relied on the principles adopted by the Court of Justice of the European Union (CJEU) on the Danish Cases 1 to clarify certain prerequisites for the application of the withholding tax (WHT) exemption under Directive 2003/49/EC (Interest and Royalty … WebOn 9 January 2024, the Danish Supreme Court issued a ruling regarding two beneficial ownership cases. These cases were submitted to the Court of Justice of the European Union for a preliminary ruling by the Danish high courts. This Alert summarizes the Supreme Court’s ruling in each case and its approach regarding beneficial ownership. WebThe four joined cases N Luxembourg 1 (), X Denmark and C Danmark 1 and Z Denmark case all involve back-to-back financing transactions, under which a Danish resident … checkered flag corporate office