Limitation of Benefits prevents treaty benefits when the main purpose of an entity or transaction is to obtain them. Limitation of Benefits denies treaty advantages to a resident or their transactions where the main purpose of creating or maintaining the resident, or of the transaction, was to obtain benefits not otherwise available; if benefits are denied on that ground the competent authority of the other Contracting State shall notify the competent authority of the resident's State of residence.
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 benefits when the main purpose of an entity or transaction is to obtain them.
Limitation of Benefits denies treaty advantages to a resident or their transactions where the main purpose of creating or maintaining the resident, or of the transaction, was to obtain benefits not otherwise available; if benefits are denied on that ground the competent authority of the other Contracting State shall notify the competent authority of the resident's State of residence.
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