Limitation of benefits: treaty advantages denied where arrangements are devised primarily to obtain tax benefits or control by non residents. The treaty preserves Contracting States' anti avoidance laws and denies its benefits where arrangements are made principally to avoid taxes. Treaty ... Summary
Limitation of benefits: treaty advantages denied where arrangements are devised primarily to obtain tax benefits or control by non residents.
The treaty preserves Contracting States' anti avoidance laws and denies its benefits where arrangements are made principally to avoid taxes. Treaty benefits for categories such as dividends, interest and royalties are not available to a resident who is controlled by non residents or where the creation or assignment of a share, debt claim, or right was undertaken mainly to take advantage of the treaty.
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