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Beneficial Ownership in case of conduit and back-to-back arrangements

March 17 2023

Open Access Video

This video discusses the beneficial ownership issues in case of conduit or back-to-back situations.

More videos in the Beneficial Ownership Series

Beneficial Ownership: How should that tax treaty term be interpreted?

Beneficial Ownership: Two Very important decisions

Beneficial Ownership: Is 'risk' a relevant factor for determination of beneficial ownership?

Beneficial Ownership: Absence of beneficial ownership clause in a tax treaty - implied inference and burden of proof (1)

Beneficial Ownership: Absence of beneficial ownership clause in a tax treaty - implied inference and burden of proof (2)

Recent Article

Variable interest on loans: Tax treaty characterization as dividends (Art. 10) or interest (Art. 11)?

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