In a context where transparency and economic substance guide the interpretation of transactions, the line between apparent ownership and beneficial ownership becomes crucial for safeguarding tax fairness and combating the abuse of the law. Despite regulatory developments and the growing sophistication of anti-avoidance tools, crucial questions remain: identifying the beneficial owner, unravelling fictitious arrangements, and defining the fine line between legitimate planning and abusive conduct.

This volume addresses these issues with legal rigour and a systematic approach, offering the reader a conceptual and practical framework to navigate the maze of rules, practices and interpretations, where legal form risks obscuring the underlying economic reality. From the analysis of conduit structures and treaty shopping to the criminal and tax implications of cross-border financial flows, right through to the role of labour outsourcing practices, the work offers a comprehensive overview of modern forms of planning and the associated legal and economic risks.

Particular attention is paid to the principle of beneficial ownership, which has now become a key criterion in tax and reputational risk management. Through an approach that combines scientific rigour with practical applicability, this volume provides a comprehensive overview of the interrelationships between law, economics and finance, serving as a key reference point for academics, professionals, business operators and public officials involved in the governance of tax compliance.