Limitation of benefits: treaty relief denied where the main purpose is to obtain treaty advantages for a resident or transaction. Article 30 preserves domestic anti avoidance provisions and denies treaty benefits where the main purpose of creating or maintaining a resident, or of a transaction, is to obtain benefits under the Agreement that would not otherwise be available; entities lacking bona fide business activities are expressly covered, and denial of benefits must be notified between competent authorities.
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: treaty relief denied where the main purpose is to obtain treaty advantages for a resident or transaction.
Article 30 preserves domestic anti avoidance provisions and denies treaty benefits where the main purpose of creating or maintaining a resident, or of a transaction, is to obtain benefits under the Agreement that would not otherwise be available; entities lacking bona fide business activities are expressly covered, and denial of benefits must be notified between competent authorities.
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