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Resumen de France: Eligibility of foreign partnerships for treaty benefits

Bruno Gouthière

  • The author discusses a court decision that is of importance because it provides, for the first time, guidelines as to the eligibility of foreign partnerships for treaty benefits and, at the same time, explicitly sets out a general principle according to which a tax treaty should be applied only to genuine beneficiaries even if the treaty does not include a "limitation on benefits" article or a "beneficial ownership" test.


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