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Limitation of benefits: treaty relief denied when the main purpose is obtaining benefits, with mandatory inter authority notification. Limitation of Benefits denies Convention benefits to a resident when the main purpose or one of the main purposes of the resident's creation, existence, or of a transaction is to obtain those benefits; if benefits are denied, the competent authority of the denying State must 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: treaty relief denied when the main purpose is obtaining benefits, with mandatory inter authority notification.
Limitation of Benefits denies Convention benefits to a resident when the main purpose or one of the main purposes of the resident's creation, existence, or of a transaction is to obtain those benefits; if benefits are denied, the competent authority of the denying State must notify the competent authority of the resident's State of residence.
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