Limitation of Benefits prevents resident entities formed primarily to secure treaty advantages from claiming treaty benefits. Article 29 denies treaty benefits to a resident entity when the main purpose or one of the main purposes of its creation was to obtain benefits under the ... Summary
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Limitation of Benefits prevents resident entities formed primarily to secure treaty advantages from claiming treaty benefits.
Article 29 denies treaty benefits to a resident entity when the main purpose or one of the main purposes of its creation was to obtain benefits under the Agreement not otherwise available, and explicitly covers legal entities not having bona fide business activities.
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TaxTMI 
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