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Prohibition of Abuse and Beneficial Ownership: Disentanglement via a Principle-Based Approach in EU Tax Law (and Beyond)

Błażej Kuźniacki & J. Kokott

Bulletin for International Taxation2025https://doi.org/10.59403/1m9hd0xarticle
ABDC B
Weight
0.41

Abstract

This article disentangles beneficial ownership (BO) from the EU law principle prohibiting the abuse of rights (Prohibition of Abuse) through a principle-based approach. It contrasts their core elements, scope and purpose, concluding that this approach clarifies their distinction within EU law and other anti-abuse measures, including PPT (MLI) and GAAR (ATAD).

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https://doi.org/https://doi.org/10.59403/1m9hd0x

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@article{błażej2025,
  title        = {{Prohibition of Abuse and Beneficial Ownership: Disentanglement via a Principle-Based Approach in EU Tax Law (and Beyond)}},
  author       = {Błażej Kuźniacki & J. Kokott},
  journal      = {Bulletin for International Taxation},
  year         = {2025},
  doi          = {https://doi.org/https://doi.org/10.59403/1m9hd0x},
}

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Prohibition of Abuse and Beneficial Ownership: Disentanglement via a Principle-Based Approach in EU Tax Law (and Beyond)

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Evidence weight

0.41

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.25 × 0.4 = 0.10
M · momentum0.55 × 0.15 = 0.08
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.