Promulgated on October 27, 2009, the Circular on How to Understand and Determine “Beneficial Owners” under Tax Treaties (the “Beneficiary Definition Circular”) clarifies the concept of “beneficial owners” under bilateral tax treaties and excludes “conduit companies” from its scope.
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Register‘Conduit companies’ are excluded from ‘beneficial owners’ under tax treaties
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China
February 2 2010
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Dr Jürgen Fegbeutel
Legal Services Director
BMW (South Africa) (Pty) Ltd
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