The Evolution of the Term “Beneficial Ownership” in Relation to International Taxation over the Past 45 Years

Journal
International
Bulletin for International Taxation 2010 (Volume 64), No. 10
This article reviews the evolution of the term “beneficial ownership” in tax treaties since its first inception 45 years ago, with special focus on whether or not the meaning has evolved away from that in the domestic law of the common law states and the implications of the recent decisions in Indofood and Prévost.