Limitation of benefits: treaty relief denied where main purpose was obtaining tax advantage, authorities assess ownership and control. Treaty relief is not available where a principal purpose of persons involved in creating or assigning income was to obtain the Agreement's tax benefits; competent authorities may consider amount and nature of the income, circumstances of derivation, stated intentions, and the identity, residence, control or beneficial ownership of those owning or handling the income.
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.
Provisions expressly mentioned in the judgment/order text.
Limitation of benefits: treaty relief denied where main purpose was obtaining tax advantage, authorities assess ownership and control.
Treaty relief is not available where a principal purpose of persons involved in creating or assigning income was to obtain the Agreement's tax benefits; competent authorities may consider amount and nature of the income, circumstances of derivation, stated intentions, and the identity, residence, control or beneficial ownership of those owning or handling the income.
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