Observations of Member Countries on difficulties raised by the OECD Draft Convention on Income and Capital. Comments received from Delegates on the OECD Draft Conventions (Art. 2 to 29) as at 2nd May 1967, and which supersedes TFD/FC/209; 9 May 1967. TFD/FC/216, p. 14. URL: www.taxtreatieshistory.org: «In our view the relief provided for under these Articles ought to apply only if the beneficial owner of the income in question is resident in the other contracting State, for otherwise the Articles are open to abuse by taxpayers who are resident in third countries and who could, for instance, put their income into the hands of bare nominees who are resident in the other contracting State. You will no doubt have noticed that our recent protocols with the United States and with Switzerland we have introduced this test of beneficial ownership which clearly reflects what was intended by the Committee when the Model Convention was prepared».
