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The Beneficial ownership in OECD’S TAX treaties

03/16/2018

The term Beneficial owner can be found in many context and because of this it should not be confused the meaning that it has in OECD’s Tax Treaties with the meaning in other rules or conventions (such as the Money Laundering Regulations). This term was introduced in three articles of the OECD’s model regarding Dividends, Interests and Royalties, to address potential difficult arising from the words “paid to … a resident” hence to clarify how these articles applies in relation to payments made to intermediaries. In fact the State of source does not have any obligation to give up its taxing rights solely because one of the incomes abovementioned was paid to a resident of a State with which the state of source has concluded a convention.
The procedure is then to go through the Model of the convention to find a definition, and then to search for an interpretation and a specification.

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