The Meaning of ‘Beneficial Owner’ in the OECD Model Tax Convention

SIFMA provides comments to the Organisation for Economic Co-operation and Development (OECD) on the OECD’s Discussion Draft – Clarification of the Meaning of “Beneficial Owner” in the OECD Model Tax Convention. SIFMA stresses the importance of providing clear guidance to OECD member states so that measures that are intended to clarify the meaning of this important concept do not inadvertently have the effect of creating rather than reducing uncertainty. A definition of beneficial ownership that does not fully take account of the realities of financial transactions and markets, where financial institutions and investors must manage their risk in the ordinary course of their businesses, would give rise to significant market disruption.