Limitation of benefits principle denies treaty benefits where arrangements have the main purpose of obtaining them through contrived arrangements. Limitation of benefits denies treaty advantages where a resident's affairs are arranged with the main purpose of obtaining those benefits; legal entities lacking bona fide business activities may be denied Agreement benefits when their structure or conduct evidences treaty-shopping.
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 principle denies treaty benefits where arrangements have the main purpose of obtaining them through contrived arrangements.
Limitation of benefits denies treaty advantages where a resident's affairs are arranged with the main purpose of obtaining those benefits; legal entities lacking bona fide business activities may be denied Agreement benefits when their structure or conduct evidences treaty-shopping.
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