The beneficial owner must be either an individual or a corporate taxpayer that is fully entitled to directly enjoy the benefits of the dividend, interest or royalty. Special purpose vehicles like conduit companies, paper box companies, pass through companies, etc. are not considered to be the beneficial owner. If the dividend, interest or royalty is paid to parties that are not considered beneficial owners, the payer is obliged under Art. 26 of the Income Tax Act to withhold income tax at a rate of 20% of the gross amount of the payment.