OECD MODEL TAX CONVENTION: REVISED …

OECD MODEL TAX convention : REVISED PROPOSALS concerning THE MEANING OF BENEFICIAL OWNER IN ARTICLES 10, 11 AND 12 19 October 2012 to 15 December 2012 1 19 October 2012 REVISED PROPOSALS concerning THE MEANING OF BENEFICIAL OWNER IN ARTICLES 10, 11 AND 12 OF THE OECD MODEL TAX convention REVISED public discussion draft On 29 April 2011, the OECD released a public discussion draft entitled Clarification of the meaning of beneficial owner in the OECD MODEL Tax convention .1In light of the comments received 2 This REVISED discussion draft includes the REVISED proposals that the Working Party has drafted. Since the changes originally proposed were almost identical for Articles 10, 11 and 12, this REVISED discussion draft focuses on the proposals made with respect to Article 10. This draft includes a summary of the comments received and an explanation of the changes made with respect to each relevant paragraph of the Commentary on that Article (as well as a new proposal for a clarifying change to the wording of paragraph 2 of Articles 10 and 11 that addresses a triangular case that was raised in some of the comments received).

oecd model tax convention: revised proposals concerning the meaning of “beneficial owner” in articles 10, 11 and 12 19 october 2012 to 15 december 2012

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