How the DGT's position has evolved
Current position
To apply exemptions or reduced rates under international treaties, the recipient must prove their status as a beneficial owner and their tax residence through certificates from the competent authorities. In the case of services or work, it is required that the work be effectively performed abroad for a non-resident entity or permanent establishment. Furthermore, there must be a tax of a similar nature in the destination country, and it cannot be a tax haven.
The DGT's position remains constant in requiring proof of beneficial owner status and tax residence to apply treaty benefits. Throughout the rulings, a systematic application of this requirement is observed for royalties, dividends, and remuneration for work performed abroad.
Analysis based on 27 of 28 rulings with a stated position. Updated 24 September 2026.