This authoritative book provides a structural, global view of evolving judicial and
doctrinal trends in the understanding of beneficial ownership in international
taxation. Błażej Kuźniacki presents a route towards an international autonomous
meaning of beneficial ownership, while also offering a comprehensive explanation of
the divergent understandings and tax policy arguments underpinning its continuing
This book provides a comprehensive, practical guide to the 6th amendment of Council Directive 2011/16/EU on administrative cooperation in the field of taxation (known as DAC6). Florian Haase offers insight and clarity into the mandatory reporting obligations imposed by DAC6 on intermediaries engaged in tax matters involving cross-border activities, and in some cases taxpayers themselves, as well as the characteristics or ‘hallmarks’ outlined in the Directive that trigger these obligations.