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The simplest solutions are often the most difficult to achieve. For years, multinationals sought to pool pension plan funds across borders to bring more efficiency to their management in terms of both governance and risk and economies of scale. Standing in the way, however, was the question of the tax treatment of pension fund dividend income. If the tax authorities of various nations were not able to look through the pooling vehicle and tax the ultimate holders of the assets, then the pensions would lose the benefit of double taxation treaties and pooling would not be tax efficient. The key, of course, was to find a tax-transparency. But for a long time, it was a quest for the Holy Grail.

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