The notion of beneficial ownership is decisive in determining whether a person qualifies for tax treaty benefits and in the allocation of the right to tax between the two contracting states in respect of royalties, dividends and interest. Given the importance of the matter, and the high value of the flow of royalties, dividends and interest internationally, it is remarkable that more than 20 years after incorporating the notion of beneficial ownership into the OECD Model Tax Convention there is still so much uncertainty in respect of the tax treaty meaning of beneficial ownership.