French Supreme Court Rules on Application of Treaty Benefits for Beneficial Owner in a Third Country
The French Supreme Court (Conseil d'Etat) on 20 May 2022 issued its decision in a case concerning the payment of royalties by a French company, "Planet", through interposed Belgian and Maltese recipients towards the use of intangibles developed by a company established in New Zealand. The tax authorities denied the application of the benefits under the treaties with Belgium and Malta on the gr…
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