Limitation of benefits prevents treaty tax relief when arrangements are primarily designed to obtain treaty advantages. Limitation of benefits disqualifies residents from treaty tax reductions or exemptions where their affairs were arranged with the primary purpose of obtaining those benefits; legal entities lacking bona fide business activities are specifically covered and thereby excluded from treaty relief.
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 tax relief when arrangements are primarily designed to obtain treaty advantages.
Limitation of benefits disqualifies residents from treaty tax reductions or exemptions where their affairs were arranged with the primary purpose of obtaining those benefits; legal entities lacking bona fide business activities are specifically covered and thereby excluded from treaty relief.
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