The Committee on Fiscal Affairs (CFA) of the Organisation for Economic Cooperation and Development (OECD) is inviting public comments on [draft changes to the Commentary on Articles 10, 11 and 12]( of the [OECD Model Tax Convention](,3746,en_2649_34897_1913957_1_1_1_1,00.html) concerning the meaning of the term “beneficial owner”.

A release from the OECD states: *“The term “beneficial owner”, as used in these Articles of the Model Tax Convention, has given rise to different interpretations by courts and tax administrations. Given the risks of double taxation and non-taxation arising from these different interpretations, the CFA has developed proposals aimed at clarifying the interpretation that should be given to that concept in the context of the Model Tax Convention.”*

Interested parties are asked to send comments on the discussion draft before 15 July 2011.

The OECD notes that the discussion draft has been prepared for the purpose of inviting comments from interested parties, and will be reviewed in the light of the comments received. It does not necessarily reflect the final views of the OECD and its member countries.