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 ... Summary
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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