Judicial influence on tax treaties

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Student’s Name Tutor Course Date Judicial influence on tax treaties The beneficial owner is an essential concept applied in tax treaties. It restricts the benefit of treaty-reduced holding back taxes on royalties, interests, dividends, and interests to the recipients who are the beneficial owners of this kind of income. The beneficial owner as a term has been embraced mostly in the bilateral tax treaties, even though it lacks its definition in any of them. Therefore, the definition of the phrase is interpreted under the Article 3(2) of the OECD Model Tax Agreement on Capital Model and Income. Since the term lacks an exact definition in the domestic tax statutes of many nations, the means through which the local courts need to develop the meaning of this treaty-initiated concept has deferred within the scholars. Understanding of this in the judicial system would be the key to evaluating the influence of the law courts on the tax treaties. Therefore, understanding this term determines the ability of the judiciary in the provision of more certainty as well as the delivery of practical solutions towards tax treaties stalemates. In the pursuit of understanding the meaning of the beneficial owner in the tax treaties, the judicial system has encountered various incidences that portray its necessity in understanding this matter which depicts its influence on the international tax treaties. This paper illustrates the significance of developing the meaning of the beneficial owner as an influence on the tax treaties where the identifiable reasons for providing certainty and provision of practical solutions are detailed respectively. It also demonstrates an example of the

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