A South African perspective on the meaning of "beneficial ownership" in Article 10 of the OECD Model Tax Convention on Income and Capital in the context of conduit company treaty shopping
The use of conduit company treaty shopping structures is often regarded as an impermissible erosion of a country’s tax base. For a developing country, such as South Africa, the protection of its tax base is an important policy consideration. Arguably, one way of combatting conduit company treaty sho...
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University of Pretoria
2018
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| Online Access: | http://hdl.handle.net/2263/65660 Jansen van Rensburg, EC 2018, A South African perspective on the meaning of "beneficial ownership" in Article 10 of the OECD Model Tax Convention on Income and Capital in the context of conduit company treaty shopping, LLD Thesis, University of Pretoria, Pretoria, viewed yymmdd <http://hdl.handle.net/2263/65660> |