Charl du Toit. The Evolution of the Term «Beneficial Ownership» in Relation to International Taxation over the Past 45 Years. Bulletin for International Taxation – Tax Treaty Monitor. IBFD. October 2010. P. 502: «Relief from tax on dividends, interest and royalties… in the country of origin will no longer depend on whether the recipient is subject to tax in the other country, but will depend on the income being beneficially owned by a resident of the other country».
