The commonalities or divergence of the meaning of beneficial owner in a treaty (International) and domestic context by Tasneem Koorowlay.
The aim of this dissertation is to establish the relevance of the international interpretation of beneficial owner to SA’s interpretation of the concept. The phrase “beneficial owner” was introduced into the South African Income Tax Act in April 2012 following an intention to align South African tax as regards dividends with international norms. The concept is applied in a domestic context by various countries and in numerous bilateral tax treaties and has been a subject of debate across numerous foreign courts.
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