OECD - Conceptual Problems of Beneficial Ownership in Respect of Agents and Nominees
- S. Jain; J. Prebble
- Bulletin for International Taxation, 2019 (Volume 73), No 1
- 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.