Limitation of benefits: treaty benefits denied where arrangement's main purpose is to obtain tax treaty advantages. Limitation of benefits bars treaty entitlement where domestic anti-avoidance measures apply; residents are not entitled if their arrangements indicate ... Summary
Limitation of benefits: treaty benefits denied where arrangement's main purpose is to obtain tax treaty advantages.
Limitation of benefits bars treaty entitlement where domestic anti-avoidance measures apply; residents are not entitled if their arrangements indicate that obtaining treaty benefits was the main purpose, and legal entities without bonafide business activities are expressly covered, allowing denial of benefits for entities lacking substance.
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