The interpretation of the term “beneficial ownership” in South Africa for international tax purposes
M.Com. (South African and International Taxation) === The term “beneficial ownership” was first included in Articles 10, 11 and 12 of the OECD’s Model Tax Convention in 1977 but it is not defined in the OECD’s Model Tax Convention and most countries do not have a definition in their domestic tax law...
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2014
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| Online Access: | http://hdl.handle.net/10210/9626 |