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; ... Summary
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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