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By Oliver R. Hoor *
On 29 April 2011, the OECD released a discussion draft (2011 Discussion Draft) on the meaning of beneficial owner in the OECD Model Tax Convention on Income and on Capital (OECD Model Tax Convention). The beneficial owner concept is found in Articles 10, 11 and 12 which deal with the taxation of dividends, interest and royalties. This article outlines (i) the purpose of the concept of beneficial owner, (ii) the developments in the guidance thereon over the last decades, and (iii) analyses the proposed modifications to the Commentary on the OECD Model Tax Convention.
I. Introduction
In essence, the beneficial owner...
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