Response to the OECD’s discussion draft on the meaning of ‘beneficial owner’

Tax Policy Bulletin ()


On 29 April 2011, the OECD released a discussion draft on the meaning of 'beneficial owner' in the OECD Model Tax Convention. The concept has given rise to different interpretations by courts and tax administrations, leading to risks of double taxation and non-taxation. The discussion draft contains new wording which aims to clarify and give further guidance around the interpretation of this term. Interested parties were asked to send their comments on the draft to the OECD by 15 July.

PwC’s response to the discussion draft is set out in this bulletin, along with commentary on the other representations made.