One solution suggested by the OECD is directed at disallowing treaty benefits to a company if it is not owned directly or indirectly by residents of the state in which the company itself is resident. It suggests that this approach may be adequate for treaties with countries which have no or very low taxation and where little substantive business activities would normally be carried on.

A variation of the look-through theory is to exclude companies resident in a contracting state from benefits under a treaty if the company is owned or controlled by residents of a third country who themselves would not qualify for similar treaty benefits.

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