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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From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal
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