Limitation of Benefits denies treaty advantages where the main purpose of an entity or transaction is tax motivated. The treaty does not affect domestic anti avoidance provisions. Treaty benefits are denied where the main purpose of creating or maintaining a resident, or ... Summary
Limitation of Benefits denies treaty advantages where the main purpose of an entity or transaction is tax motivated.
The treaty does not affect domestic anti avoidance provisions. Treaty benefits are denied where the main purpose of creating or maintaining a resident, or of undertaking a transaction, was to obtain benefits under the treaty. The Article covers legal entities without bona fide business activities. When benefits are denied under this Article, the competent authority of the other Contracting State shall be notified.
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