Interpretation of the concept of Beneficial Ownership: Trends, tensions, contradictions

Aka, Gali Folawiyo (2011) Interpretation of the concept of Beneficial Ownership: Trends, tensions, contradictions. Masters thesis, Institute of Advanced Legal Studies, School of Advanced Study.

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This paper adopts the view that the beneficial ownership concept in taxation should not be interpreted by reference to domestic laws of any state as provided under Article 3(2) of the OECD Model Code. It argues that because the beneficial ownership concept is a specific anti-avoidance provision, it should take its colour from an International Fiscal Meaning. Contracting State may then introduce elaborate anti-abuse provisions when negotiating tax treaties.

Item Type	Thesis (Masters)
Additional Information	Masters dissertation (distinction) - MA in Taxation (Law, Administration and Practice) (TAX).
Keywords	Taxation - Law and legislation, International tax treaties, Tax codes, Double taxation treaties, International Trade, OECD, Organisation for Economic Co-operation and Development
Subjects	Law
Divisions	Institute of Advanced Legal Studies
Date Deposited	08 Feb 2013 10:57
Last Modified	05 Aug 2024 23:40