Effectiveness of the Beneficial Ownership Test in Conduit Company Cases

Download or read book Effectiveness of the Beneficial Ownership Test in Conduit Company Cases written by Saurabh Jain and published by . This book was released on 2013 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt: "This book examines the conflict between the general policy of double tax treaties embodied in the beneficial ownership requirement and the concept of corporations. The work highlights the shortcomings of surrogate tests with the help of analyses of reported conduit company cases. It offers an alternative approach for interpreting and applying the beneficial ownership test. It contains a critique of the work of the OECD Committee on Fiscal Affairs before the insertion of the term, and suggests appropriate amendments to relevant parts of the official Commentary on the OECD Model Tax Convention."--Extracted from publisher website on May 20, 2015.