https://www.taxtmi.com/manuals?id=4514 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. en-us Fri, 01 Mar 2024 18:03:00 +0530 Wed, 14 Aug 2024 10:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4514 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. Manuals Income Tax Fri, 01 Mar 2024 18:03:00 +0530 https://www.taxtmi.com/manuals?id=4514