United Nations Model Tax Convention (2011). Commentary to Art 1. § 47–56. P. 53–61.

Ibid. § 10–20. P. 63–69.

OECD Model Tax Convention on Income and on Capital: Condensed Version. Paris, OECD Publishing, 2014. Commentary to Art. 1. § 17. P. 65–66.

Art. 3.1.(n) of the United Kingdom – United States Income Tax Treaty (2001) (as amended through 2002): «The term „conduit arrangement“ means a transaction or series of transactions: (i) which is structured in such a way that a resident of a Contracting State entitled to the benefits of this Convention receives an item of income arising in the other Contracting State but that resident pays, directly or indirectly, all or substantially all of that income (at any time or in any form) to another person who is not a resident of either Contracting State and who, if it received that item of income direct from the other Contracting State, would not be entitled under a convention for the avoidance of double taxation between the state in which that other person is resident and the Contracting State in which the income arises, or otherwise, to benefits with respect to that item of income which are equivalent to, or more favourable than, those available under this Convention to a resident of a Contracting State; and (ii) which has as its main purpose, or one of its main purposes, obtaining such increased benefits as are available under this Convention».