Historical introduction to the test of dominion in the context of double tax treaties Saurabh Jain and John Prebble
By: Jain, Saurabh
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Material type: 
ArticlePublisher: 2018Subject(s): DOBLE IMPOSICION | PROPIEDAD | IMPUESTOS | SOCIEDADES | BENEFICIARIO EFECTIVO | TRATADOS INTERNACIONALESOnline resources: Click here to access online
In:
Bulletin for International Taxation v. 72, n. 8, August 2018, p. 488-492Summary: The term "dominion" represents the right to decide how to use income or property. Courts have considered the presence of dominion to conclusively indicate that an interposed company is the beneficial owner and therefore entitled to treaty benefits. This article analyses from a historical perspective how dominion developed as a test in conduit company cases.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | BIT/2018/8-3 (Browse shelf) | Available | BIT/2018/8-3 |
Disponible únicamente en formato electrónico.
Resumen.
The term "dominion" represents the right to decide how to use income or property. Courts have considered the presence of dominion to conclusively indicate that an interposed company is the beneficial owner and therefore entitled to treaty benefits. This article analyses from a historical perspective how dominion developed as a test in conduit company cases.
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