Research on the Identification of "Beneficial Owner" in Tax Treaties: Based on Case Analysis

Abstract

Nowadays, with the development of cross-border trade and the increase of tax agreements signed between countries, money laundering and tax treaty abuse crime is more and more rampant. The beneficial ownership rule first introduced in the last century by the OECD is an effective way to curb it. Based on introducing the origin and development of beneficial ownership rules, this paper analyzes the differences in international identification standards, then adopts the case analysis method to discuss the differences in the identification standards of beneficial ownership in tax treaties, and finally puts forward suggestions for the construction of a rational identification standard for beneficial ownership.