Establishing the status of the beneficial owner of income: A scientific approach
One of the most common types of tax disputes today concerns the denial of beneficial owner status to a non-resident recipient of income sourced from Ukraine.
Such status is a prerequisite for obtaining a reduced withholding tax rate on non-resident income, including dividends, interest, and royalties, under most double taxation treaties.
At first glance, the determination of beneficial owner status in a particular case may appear somewhat stochastic, that is, difficult to predict and based not on clear and transparent criteria, but rather on subjective assessment.
In reality, however, there are criteria – and they are grounded in a scientific approach. This is precisely what we explore in our new article.
The full version of the article is available in Ukrainian by the link.
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