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Interpretation of the concept of Beneficial Ownership: Trends, tensions, contradictions

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Interpretation of the concept of Beneficial Ownership: Trends, tensions, contradictions


This paper adopts the view that the beneficial ownership concept in taxation should not be interpreted by reference to domestic laws of any state as provided under Article 3(2) of the OECD Model Code. It argues that because the beneficial ownership concept is a specific anti-avoidance provision, it should take its colour from an International Fiscal Meaning. Contracting State may then introduce elaborate anti-abuse provisions when negotiating tax treaties.

Aka, Gali Folawiyo (2011) Interpretation of the concept of Beneficial Ownership: Trends, tensions, contradictions. Masters thesis, Institute of Advanced Legal Studies, School of Advanced Study.


Item Type: Thesis (Masters)
Additional Information: Masters dissertation (distinction) - MA in Taxation (Law, Administration and Practice) (TAX).
Subjects: Law
Keywords: Taxation - Law and legislation, International tax treaties, Tax codes, Double taxation treaties, International Trade, OECD, Organisation for Economic Co-operation and Development
Divisions: Institute of Advanced Legal Studies
Collections: Theses and Dissertations > Dissertation
IALS Students
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URI: http://sas-space.sas.ac.uk/id/eprint/4717
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