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

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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

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