Limitation of Benefits: treaty benefits denied where main purpose is tax avoidance, including entities without genuine business activities. Article 28B permits a Contracting State to apply domestic anti-avoidance measures notwithstanding the treaty; it denies treaty benefits where the ... Summary
Limitation of Benefits: treaty benefits denied where main purpose is tax avoidance, including entities without genuine business activities.
Article 28B permits a Contracting State to apply domestic anti-avoidance measures notwithstanding the treaty; it denies treaty benefits where the resident's affairs were arranged with the main purpose, or one of the main purposes, of obtaining treaty benefits, and expressly covers legal entities that do not carry on bona fide business activities.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 1
Join Channel
TaxTMI 
