Download or read book Beneficial Ownership of Royalties in Bilateral Tax Treaties written by Charl P. Du Toit and published by . This book was released on 1999 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: In-depth analysis of the meaning of beneficial ownership in respect of royalties. By referring to the history and circumstances surrounding the decision to adopt the notion of beneficial ownership as an anti- treaty abuse measure, and by following the steps for treaty interpretation as prescribed by the Vienna Convention on the Law of Treaties, the author concludes that the meaning of beneficial ownership as determined can be applied universally for tax treaty purposes.