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of <h1>Beneficial Ownership Limits Tax Treaty Benefits to True Owners, Excluding Conduits and Intermediaries Under OECD Guidelines.</h1> The concept of beneficial ownership in tax treaties restricts treaty benefits to those who are the true beneficial owners of income, excluding conduit companies and intermediaries like agents or nominees. This principle is applied in various tax treaty articles concerning interest, royalties, dividends, and fees for services, as outlined by organizations such as the OECD, US, and UN. The term 'beneficial owner' is not explicitly defined in treaties, but generally refers to the entity with control over the economic benefits of an asset. The OECD commentary emphasizes that treaty benefits are not automatically granted just because income is received by a resident of a contracting state.
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