Техническую модель - The U.S. Model Income Tax Convention and Model Technical
Abstract: The concept of beneficiary ownership is among the most debatable concepts in the modern theory of international tax law. Initially the term beneficiary owner has appeared in the trust law of the Great Britain in order to distinguish between the person having basic economic profits from property or trust income and a formal owner of property. However, later this concept was transferred into the international tax law, and it became a popular norm against unlawful use of treaties against double taxation treaty shopping. The third type of concept of beneficiary owner belongs to the spheres of administrative and financial law, and it is connected to the issues of disclosure of a final beneficiary in a corporate structure.
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