INTERNATIONAL TAX FOCUS – FEBRUARY 2024
1. Beneficial ownership requirements under the Interest&Royalty Directive According to the Italian Supreme Court decision no. 510 and 521 of 8 January 2024: in the context of the Interest&Royalty Directive (Directive 2003/49/EC), the notion of beneficial owner is to be understood as a substantive rule aimed at allocating taxing power, … Read more
