Asia Pacific Tax Notes: A fine balance - managing tax in a changing world

This issue begins with a lead article that discusses the concept of "beneficial ownership" and its application in a treaty context. With investment increasing in the region and the common use of multi-tier investment structure by businesses to manage their global tax exposure, tax authorities in many of the jurisdictions in the region are closely scrutinising the use of conduit companies, which have little commercial substance but are merely created for the purpose of obtaining a treaty benefit.

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