Essays about: "judicial interpretation of the concept beneficial owner"

Found 1 essay containing the words judicial interpretation of the concept beneficial owner.

  1. 1. Per Aspera Ad Astra: Towards the International Fiscal Meaning of the Concept 'Beneficial Owner'

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Anna Vitko; [2011]
    Keywords : autonomous treaty meaning; domestic law meaning; discussion draft of 29 April 2011; beneficial owner; judicial interpretation of the concept beneficial owner ; Law and Political Science;

    Abstract : The term ‘beneficial owner’ was first internationally introduced by the OECD in the Model Convention in 1977 and since that time it serves as one of the anti-abuse rules directly provided for in double tax treaties. The concept is critical for determining the eligibility of a person for the tax treaty benefits and for the allocation of taxing rights between two contracting states with regard to dividends, interest or royalties income. READ MORE