目次

1 Introduction 2 General Rules and Principles concerning the Interpretation of Tax Treaties 3 Beneficial Ownership in the OECD Model 4 Scholarly Discussion 5 Country Reports 6 A Domestic Law Meaning of Beneficial Ownership? 7 Beneficial Ownership in EU Legislation 8 Other Aspects to Consider in Determining the Meaning of Beneficial Ownership 9 Specific Approaches to Beneficial Ownership and Their Particularities 10 How Should Beneficial Ownership Ideally Be Interpreted? 11 Conclusion: Back to the Roots! Bibliography Table of Cases Index