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The History and Relevance of the Beneficial Ownership Concept in Tax Treaties ? Specifically in the context of the Introduction of the Principal Purpose Test
The term Beneficial Ownership was primarily introduced to prevent treaty shopping and to ensure that only those liable to tax could claim treaty advantages. However, the term is not explicitly defined in the Organisation for European Economic Co-operation Model Tax Convention on Income and on Capita...
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| Format: | Thesis |
| Language: | English |
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Department of Finance and Tax
2024
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