The Concept of Beneficial Ownership in Portugal
In 2023, two arbitration tribunals issued the first decisions discussing the concept of beneficial ownership in Portugal (cases 776/2022-T and 538/2022-T). This article examines whether these decisions are aligned with CJEU case law – in particular the Danish cases – and with the rules governing treaty interpretation under the Vienna Convention (1969).
Authors
- Ritada Cunha
Publication Details
- Journal
- Bulletin for international taxation
- Published
- 2025-08-30
- DOI
- https://doi.org/10.59403/ryr5vb
- Primary Topic
- Legal principles and applications
- Type
- article
- Field-Weighted Citation Impact
- 0.00