There has been a significant rise in controversy around the world in recent years centred on the topic of the beneficial owner test which appears in the dividends, interest and royalties articles of most double tax treaties. Richard Collier, of PwC, explores the work of the OECD in this area to date and what the future holds, calling for greater clarity on the concept.
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The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year