Beneficial Ownership – Anti-treaty shopping measures

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..... ersons who are beneficial owners of income. This concept has been referred in various tax treaty Articles relating to interest, royalty, fees for technical services, fees for included services, dividend of model tax treaty of OECD, US, UN. Provision of beneficial ownership restricts the treaty benefit to the beneficial owner and excludes the concessional withholding tax benefit from the legal owne .....

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..... sive work to bring more clarity to this concept. The OECD Commentary makes it very clear that that source state is not compelled to give the benefit of Article 10,11 and 12 just because the income is received by a resident of the other contracting state. The recipient must be the beneficial owner of the income, and this concept excludes conduit companies, agents and nominees. - Manuals - Ready r .....

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