Substance in International Tax Law: DEMPE Approach, Substantial Activity Requirement and Beneficial Ownership

In a thoroughgoing investigation using the practical example of an IP company, the author provides detailed and precise answers to the following questions:

• What substance is necessary to be entitled to intangible-related returns?

• What substance is necessary to benefit from preferential IP regimes or no or only nominal tax jurisdictions?

• What substance is necessary to collect royalties free from withholding taxes?

Given the need to agree on a common understanding of substance in international tax law in order to avoid costly tax disputes, this important book is unmatched for the clear light it sheds on the most relevant substance requirements regarding intangibles. It will prove invaluable to tax practitioners and in-house counsel who are dealing with cross-border transactions concerning intangibles.