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OECD launches consultation on draft changes
The Organisation for Economic Co-operation and Development (OECD) Committee on Fiscal Affairs has launched a consultation on draft changes to the commentary on articles 10 (dividends), 11 (interest) and 12 (royalties) of the OECD Model Tax Convention concerning the meaning of the term ‘beneficial owner’.
The term, as used in the model convention, has given rise to different interpretations by courts and tax administrations. Given the risks of double taxation and non-taxation arising from these interpretations, the OECD has developed proposals aimed at clarifying the interpretation that should be given to that concept in the context of the convention.
Comments on the proposed amendments should be emailed before 15 July.
