The Ministry of Finance published today guidelines on the application of Article 12 of Law 3943/2012 on the definition of 'tax residence" and the rules on the change of tax residence (Circular 1142/2012).
The circular with the guidelines comes with a 14-month delay (the provisions it deals with were approved by the Parliament in March 2011) and it is very much welcome. It provides insight on the approach the Ministry is going to take in the application of  the relevant provisions but it does not solve any of the hermeneutical or practical problems that have been identified by practitioners. 

The Ministry of Finance issued today a circular (Circular 1144/2012) providing guidance on the interpretation and application of the Royalties article of the double tax conventions that Greece has entered into with Hungary and the Czech Republic. The Ministry essentially extends the application of Circular 1024/2011 on the interpretation and application of Article 12 of the DTC between Greece and Finland to the corresponding provisions of the DTCs with Hungary and the Czech Republic.

The Institute for Austrian and International Tax Law of WU (Vienna University of Economics and Business)is organizing a Conference on “Beneficial Ownership”.

The Conference aims at discussing recent developments of the term Beneficial Ownership by presenting the most interesting cases, which have been decided all over the world, and discussing the recently published OECD Discussion Draft on the meaning of the term Beneficial Owner. Outstanding experts of 14 jurisdictions will present the most relevant decisions from their countries. Furthermore, the meaning of the term Beneficial Owner used in European Tax Law in comparison to its meaning in Tax Treaty law will be assessed. The main topics identified have been clustered into eight “baskets”, which will be dealt with in eight conference sessions:

Session 1: Beneficial Ownership – Broad vs. Narrow Interpretation I
Session 2: Beneficial Ownership – Broad vs. Narrow Interpretation II
Session 3: Beneficial Ownership without Specific Beneficial Ownership Provision
Session 4: Beneficial Ownership as Anti Abuse Provision
Session 5: Beneficial Ownership and Domestic Law
Session 6: Beneficial Ownership as Allocation of Income Rule
Session 7 : Beneficial Ownership and EU Law
Session 8: Beneficial Ownership: OECD Discussion Draft

Detailed information on the speakers, the particular cases that will be presented and on how to participate are included in the conference programme.