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The meaning of "beneficial ownership" for special purpose vehicles
Corporate entities commonly incorporate offshore special purpose vehicles to purchase shares or issue debt securities.
Special purpose vehicles are usually strategically located in low tax territories, but in order to take advantage of the favourable tax rates, it is vital to prove that the special purpose vehicle is the "beneficial owner" of the income earned.
In this article, first published in Taxation Today, Bell Gully solicitor Fiona King discusses the concept of "beneficial ownership" and two recent decisions which could have important ramifications for a variety of common corporate structures.
To read this article, click here.
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Mathew McKay
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David Simcock
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Willy Sussman
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John Bassett
Senior Associate
