Limitation of benefits: treaty access barred when primary purpose is obtaining treaty benefits. The provision denies treaty benefits to a resident whose affairs were arranged so that the primary purpose was to obtain those benefits; legal entities ... Summary
Limitation of benefits: treaty access barred when primary purpose is obtaining treaty benefits.
The provision denies treaty benefits to a resident whose affairs were arranged so that the primary purpose was to obtain those benefits; legal entities lacking bona fide business activities are explicitly covered. It operates notwithstanding other treaty articles and serves to prevent treaty shopping by conditioning entitlement to benefits on substantive commercial activity and absence of primary intent to secure treaty advantages.
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