Conceptual aspect of beneficial ownership in the context of property law

Jain, Saurabh and QC, John Prebble (2018) Conceptual aspect of beneficial ownership in the context of property law. Bulletin for International Taxation, 72 (10).

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The Conduit Companies Report draws an analogy between cases involving nominees and agents on one hand, and conduit companies cases on the other, based on the fact that, they all pass income to a third party. The Conduit Companies report transposes the dominion test from cases concerning nominee and agents to conduit company cases. It is, however, illogical to draw such an analogy.

Nominees or agents receive income on behalf of its owner. For this reason, in property law a nominee or agent must pass passive income on to the person on whose behalf the nominee or agent receives it. It follows that nominees or agent lack dominion.

Item Type: Article
Keywords: Beneficial Ownership | Conduit Companies Report | Dominon, Withholding Tax | Real Madrid F.C v Oficina Nacional de Inspección | Ministre de l’Economie | Des Finances et de l’Industrie v Bank of Scotland
Subjects: Social Sciences and humanities > Social Sciences > Law and Legal Studies
JGU School/Centre: Jindal Global Law School
Depositing User: Mr Sombir Dahiya
Date Deposited: 28 Apr 2022 07:14
Last Modified: 28 Apr 2022 07:14
Official URL:


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