Limitation of benefits denies treaty advantages when the primary purpose is to obtain them, including shell entities. Limitation of Benefits: Treaty benefits are denied where the primary purpose, or one of the primary purposes, of a resident or a person connected with that resident was to obtain benefits under the Agreement; this applies notwithstanding other provisions and expressly covers legal entities without bona fide business activities.
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 denies treaty advantages when the primary purpose is to obtain them, including shell entities.
Limitation of Benefits: Treaty benefits are denied where the primary purpose, or one of the primary purposes, of a resident or a person connected with that resident was to obtain benefits under the Agreement; this applies notwithstanding other provisions and expressly covers legal entities without bona fide business activities.
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