Abstract
Beneficial owner is one of the most important concepts used in tax treaties. It limits the benefit of treaty-reduced withholding taxes on dividends, interest and royalties to recipients who are beneficial owners of such income. The term has been adopted in most bilateral tax treaties, but defined in none. Its meaning is thus left to be interpreted under Art. 3(2) of the OECD Model Tax Convention on Income and on Capital (the Model). Because the term has no specific meaning in the domestic tax law of most countries, the way in which domestic courts should interpret this treaty-originated concept has been the subject of much scholarly debate.
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