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Beneficial Ownership – Anti-treaty shopping measures

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Full Text of the Document

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....ns who are "beneficial owners' of income. This concept has been referred in various tax treaty Articles relating to interest, royalty, fees for technical services, fees for included services, dividend of model tax treaty of OECD, US, UN. Provision of beneficial ownership restricts the treaty benefit to the beneficial owner and excludes the concessional withholding tax benefit from the legal owner ....