The Concept of Beneficial Ownership in the OECD Model Tax Convention

This research addresses the beneficial ownership concept which is introduced by the OECD Model Convention and included in double tax treaties to combat treaty abuse. This work aims to contribute to development of the concept of “beneficial ownership” as an economic and legal instrument of granting tax benefits to taxpayers who are entitled to them. Elements of a potential authorized OECD approach on beneficial ownership are introduced in this research.