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
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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