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OECD - Conceptual Problems of Beneficial Ownership in Respect of Agents and Nominees

Country:
International,OECD
Author:
S. Jain; J. Prebble
Issue:
Bulletin for International Taxation, 2019 (Volume 73), No 1
Published:
13 November 2018
The Conduit Companies Report and certain courts have considered that the presence of dominion automatically indicates that an interposed company is not a conduit. This article argues that they have been misled by the official commentary on articles 10, 11 and 12 of the OECD Model as it stood in 1977.
 
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