The Supreme Administrative Court of the Czech Republic recently ruled on the concept of beneficial ownership in relation to royalty payments. The case involved a UK-based company that provided sublicenses to a Czech company. The UK was a part of the EU at the time and the UK company claimed an exemption on the royalty payments for the sublicenses under the EU Interest and Royalty Directive. However, the UK company's beneficial ownership of the royalties and its eligibility for the exemption were challenged because the company was obliged to pay nearly all of the royalty funds received to other related...