Limitation of benefits prevents treaty advantages where entities are created to obtain treaty benefits or lack genuine business activities. The treaty preserves domestic anti evasion measures. An enterprise is ineligible for treaty benefits if its creation was principally aimed at securing treaty advantages not otherwise available. Entities lacking bona fide business activities are specifically covered and treated as outside entitlement to the treaty's benefits.
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 prevents treaty advantages where entities are created to obtain treaty benefits or lack genuine business activities.
The treaty preserves domestic anti evasion measures. An enterprise is ineligible for treaty benefits if its creation was principally aimed at securing treaty advantages not otherwise available. Entities lacking bona fide business activities are specifically covered and treated as outside entitlement to the treaty's benefits.
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