This Master Class will concentrate on the evolvement of the definition of the beneficial owner, with particular importance to the analysis made by AG Kokott and the Court of Justice of the European Union in recent cases, and how this guidance could be applied in practice. In addition, in light of the entry into force of the MLI affecting a number of Malta’s tax treaties, and the inclusion of the principal purpose test in such covered tax agreements, the class will analyse the new test, the Commentary provided by the OECD, and its expected application.
John is a Partner, Tax Services, with KPMG in Malta. He joined KPMG in 2007, after graduating as a Doctor of Laws, and has completed an Advanced Masters in International Taxation at the International Tax Centre, University of Leiden. John advises a variety of multinationals and high net worth individuals on their international corporate structures, as well as focuses on advising retirement scheme administrators on their operations in Malta. John provides in-house training on soft skills and technical matters, both in Malta and for the KPMG network at large. He is a lecturer on the Malta Institute of Taxation’s Tax Courses and is a speaker at various seminars. John has chaired the Institute’s Direct Tax Technical Committee since 2017.
Ruth is a warranted lawyer and graduated with a Doctor of Laws from the University of Malta in 2016. She read her Advanced Masters in International Taxation at the International Tax Centre, University of Leiden in the Netherlands and graduated cum laude in 2018. In 2015 Ruth joined KPMG Malta and is currently an Assistant Manager within the international tax advisory team, being particularly involved in the provision of direct tax advisory services to international corporate clients. Ruth also regularly delivers classes in various courses relating to international tax.