Limitation of benefits rule: treaty benefits denied where main purpose of an entity or transaction was to obtain treaty advantages. Article 29 provides that benefits of the Agreement are not available to a resident of a Contracting State, or in respect of any transaction by such a resident, if the main purpose or one of the main purposes of creating or operating the resident or of the transaction was to obtain benefits under the Agreement that would not otherwise be available.
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 rule: treaty benefits denied where main purpose of an entity or transaction was to obtain treaty advantages.
Article 29 provides that benefits of the Agreement are not available to a resident of a Contracting State, or in respect of any transaction by such a resident, if the main purpose or one of the main purposes of creating or operating the resident or of the transaction was to obtain benefits under the Agreement that would not otherwise be available.
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