{"id":"W2112145622","doi":"","title":"The Meaning of 'Beneficial Ownership' in Double Tax Agreements","year":2009,"lang":"en","type":"article","venue":"SSRN Electronic Journal","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":1,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Meaning (existential); Multinational corporation; Statutory law; Tax treaty; Double taxation; Convention; Treaty; Income tax; Law and economics; Position (finance); Political science; Original meaning; Interpretation (philosophy); Economics; Law; Business; Public economics; Tax law; Finance; Linguistics","routes":{"ca_aff":false,"ca_fund":false,"ca_venue":false,"about_ca":true,"invisible_to_affiliation_only":true},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"codex-gemma-dda1882f352a","candidate_categories":[],"consensus_categories":[],"category_scores_codex":[0.001217945,0.00009371847,0.0001161967,0.0001522989,0.0002122603,0.0001701587,0.0002647119,0.00003486449,0.00003718548],"category_scores_gemma":[0.00005290668,0.00006316363,0.00006235994,0.0003091968,0.00001887242,0.0005197724,0.00002217557,0.0006178248,0.0000348524],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.0001413274,"about_ca_system_score_gemma":0.0001457793,"about_ca_topic_candidate":false,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.000702003,"about_ca_topic_score_gemma":0.006027388,"domain_scores_codex":[0.9984302,0.00001106739,0.0002883206,0.00009364039,0.0002581225,0.0009186474],"domain_scores_gemma":[0.9994737,0.000014091,0.0003333642,0.00009040635,0.00008140181,0.000007016288],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"theoretical_or_conceptual","study_design_gemma":"theoretical_or_conceptual","study_design_scores_codex":[0.0001221409,0.00004580296,0.004523908,0.000003677011,0.00001924181,0.000001425235,0.00009503563,0.00009654144,0.0003331613,0.9653134,0.0001302101,0.02931542],"study_design_scores_gemma":[0.004348565,0.0001633339,0.01986315,0.00010708,0.00006567757,0.00002133028,0.007180935,0.0008862161,0.0004291959,0.8014979,0.1650011,0.0004355826],"study_design_candidate":"theoretical_or_conceptual","study_design_consensus":"theoretical_or_conceptual","genre_codex":"empirical","genre_gemma":"empirical","genre_scores_codex":[0.924125,0.001354888,0.0002975284,0.003859249,0.0003524919,0.0001768234,2.047562e-7,0.0000327672,0.06980101],"genre_scores_gemma":[0.9972149,0.0002054751,0.00001219353,0.0002790403,0.0006917614,0.000001043929,0.000001464103,0.000007316889,0.001586795],"genre_candidate":"empirical","genre_consensus":"empirical","teacher_disagreement_score":0.1648709,"threshold_uncertainty_score":0.3363424,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.01421071313667366,"score_gpt":0.2417639911371569,"score_spread":0.2275532780004833,"validation_status":"score_only:v0-immature-baseline","note":"Baseline scores from an immature model (maturity gate not passed). Scores rank; they never assert a category."}}