International - Beneficial Ownership and the Contractual Obligation of an Interposed Company to Pass On Income
- S. Jain; J. Prebble
- Bulletin for International Taxation, 2018 (Volume 72), No 12
- 15 October 2018
This article argues that an interposed company may be under a contractual obligation to pass on income to a resident of a third state. Such a company would still possess dominion over the income. However, the absence of such an obligation is inconclusive for determining whether an interposed company is a conduit.