Год выпуска: 2014 Автор: Ahmet Emrah Gecer Издательство: LAP Lambert Academic Publishing Страниц: 56 ISBN: 9783659609466
Описание
Notwithstanding there have been a number of studies regarding the concept of beneficial ownership conducted by international organisations and distinguished scholars, the meaning of the term still remains ambiguous. To tackle the issue, the OECD has recently attempted to clarify the meaning of beneficial ownership concept. It is indicated that the initiation has made a constructive contribution to the subject but having said that a further clarification is required to provide an internationally well-accepted application. Particularly, it should be addressed that the beneficial ownership is distinguished from other anti-avoidance provisions and the distinction between related and unrelated obligations so as to determine the beneficial owner of the income concerned. This paper critically examines the notion of beneficial owner in the light of the historical background and the recent developments of the term. As a result of this paper, the author has developed a “practical matter test”:...
