Conduit companies, beneficial ownership, and the test of substantive business activity in claims for relief under double tax treaties

Conduit companies, beneficial ownership, and the test of substantive business activity in claims for relief under double tax treaties

If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is no m...

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Bibliographic Details
Main Authors: Jain, Saurabh, Prebble, J., Bunting, K.
Format: Journal Article
Published: 2013
Online Access:https://www.business.unsw.edu.au/About-Site/Schools-Site/Taxation-Business-Law-Site/Documents/PREBBLE-John-et-al-Conduit-Companies-Beneficial-Ownership-and-the-Test-of-Dominion-in-Claims.pdf
http://hdl.handle.net/20.500.11937/90472

Internet

https://www.business.unsw.edu.au/About-Site/Schools-Site/Taxation-Business-Law-Site/Documents/PREBBLE-John-et-al-Conduit-Companies-Beneficial-Ownership-and-the-Test-of-Dominion-in-Claims.pdf
http://hdl.handle.net/20.500.11937/90472

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