Paul Radcliffe and Mark Semple consider whether the OECD’s latest proposals on ‘beneficial ownership’ represent the end of the debate on this issue or just another step towards the end.
The question of what it means to be the beneficial owner has been an on-going debate for a while now. It feels at times like a long-running soap opera with a vaguely comprehensible storyline characters and issues that we’ve become familiar with together with the odd plot twist. The latest step in the tale came with the OECD’s publication on 19 October 2012 of their revised proposals regarding the meaning of ‘beneficial owner’ for the purposes of articles 10 11 and 12 of the OECD Model Tax Convention....
