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La cláusula del beneficiario efectivo en los convenios de doble imposición internacional

Authors: Sanavio Julbe, Alicia;

La cláusula del beneficiario efectivo en los convenios de doble imposición internacional

Abstract

In this globalised world, we could venture to say that it is impossible for tax regulations to keep pace with the development of society and, therefore, with the needs of the law. As a result, several gaps and loopholes are opening up in our legal system which can lead to abuse of the law in tax matters, especially in terms of tax avoidance and evasion. To combat this problem typical of international law, several tools have been created, including the beneficial owner clause. The aim of this paper is to delve deeper into this concept, to try to delimit what is meant by beneficial owner, a term that has not always been so clear and, in fact, has given rise to several jurisdictional debates. In order to achieve this, we will look at the fundamental role played by interpretation in law, analysing the most paradigmatic judgments in both the national and international spheres.

Keywords

Jurisprudencia internacional, Beneficiario efectivo, CDU::3 - Ciencias sociales::33 - Economía

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selected citations
These citations are derived from selected sources.
This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Citations provided by BIP!
popularity
This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
BIP!Popularity provided by BIP!
influence
This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Influence provided by BIP!
impulse
This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
BIP!Impulse provided by BIP!
0
Average
Average
Average
Green
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