| Untitled Document
THE
OECD Committee on Fiscal Affairs (CFA) has invited public comments on draft
changes to the Commentary on Articles 10, 11 and 12 of the OECD Model Tax
Convention concerning the meaning of the term “beneficial owner”.
The
term “beneficial owner”, as used in these Articles of the Model Tax Convention,
has given rise to different interpretations by courts and tax administrations.
Given the risks of double taxation and non-taxation arising from these different
interpretations, the CFA has developed proposals aimed at clarifying the
interpretation that should be given to that concept in the context of the Model
Tax Convention.
This
discussion draft includes the proposed changes to the Commentary on Articles 10,
11 and 12 of the Model Tax Convention. The Committee has invited interested
parties to send their comments on this discussion draft before 15 July
2011.
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