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By Oliver R. Hoor *
On 29 April 2011, the OECD released a discussion draft (“2011 Discussion Draft”) on the meaning of “beneficial owner” in the OECD Model Tax Convention on Income and on Capital (“OECD Model Tax Convention”). In light of the 39 public comments received on this discussion draft, the OECD Committee on Fiscal Affairs – through its Working Party 1 on Tax Conventions and Related Questions – made a number of changes to its initial proposals and released a revised discussion draft on 19 October 2012 (“Revised Discussion Draft”). This article outlines the most important changes to the proposals provided in the 2011 Discussion Draft.
I. Introduction
The “beneficial owner” concept is essentially an anti-abuse rule designed to...
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