Beneficial ownership limits treaty tax relief to true economic recipients, excluding conduit entities, agents and nominees. Beneficial ownership conditions access to treaty withholding tax benefits by restricting concessions to the beneficial owner of income rather than to legal holders or conduits. The inquiry centers on freedom to use capital or income and who controls allocation of yields; intermediaries, agents and nominees are excluded. OECD commentary stresses that source states need not grant treaty relief merely because income is paid to a resident if that recipient is not the beneficial owner, aiming to prevent treaty shopping by conduit arrangements.