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Beneficial ownership and the current developments within the OECD

Beneficial ownership and the current developments within the OECD. Prof. Dr. Alain Steichen University of Luxembourg Bonn Steichen & Partners. The balancing act. Introduction. Developments over time. Developments over time. Developments over time.

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Beneficial ownership and the current developments within the OECD

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  1. Beneficial ownership and the current developments within the OECD Prof.Dr. Alain Steichen University of Luxembourg Bonn Steichen & Partners

  2. The balancing act

  3. Introduction

  4. Developments over time

  5. Developments over time

  6. Developments over time

  7. Relevance of domestic law for interpreting the concept of beneficial ownership

  8. Relevance of domestic law for interpreting the concept of beneficial ownership

  9. Attribution of income Third country Residence country Source country

  10. OECD changes to the Commentary (2013)

  11. OECD changes to the Commentary (2013)

  12. OECD changes to the Commentary (2013)

  13. OECD changes to the Commentary (2013)

  14. Case 1 - related/unrelated obligations ❶ Deposits Interest Loan Interest, no WHT

  15. Case 2 - related/unrelated obligations Deposits Interest Guarantee Interest, no WHT Loan

  16. Case 3 - related/unrelated obligations Guarantee Cash collateral Interest Loan Interest, no WHT

  17. Case 4 - related/unrelated obligations Interest Guarantee State bond collateral Loan Interest, no WHT

  18. Conclusion

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