The online commentary on Art. 7 (Business Profits) extensively discusses several important and intricate issues. It covers a large number of court decisions from many jurisdictions.
The discussion is designed and structured for professionals in law firms, accounting firms, and multinational corporations across the world.
The Commentary is divided into the following chapters:
- Introduction;
- Autonomous interpretation;
- Can a tax residence certificate (TRC) be accepted as proof for beneficial ownership?
- Absence of beneficial ownership clause in a tax treaty: implied inference and burden of proof;
- Recipient versus beneficial owner;
- Legal owner versus beneficial owner;
- Implications in case of agents, nominees, conduit companies, etc.; and
- Burden of proof.