Treaty benefit limitation: domestic anti-avoidance rules prevail and benefits denied where main purpose is treaty advantage. The Agreement allows a Contracting State to apply its domestic anti-avoidance and anti-evasion rules irrespective of the Agreement; denies treaty benefits where obtaining those benefits was the main purpose or one of the main purposes of the resident's arrangements; and covers legal entities that do not have bona fide business activities.
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.
Treaty benefit limitation: domestic anti-avoidance rules prevail and benefits denied where main purpose is treaty advantage.
The Agreement allows a Contracting State to apply its domestic anti-avoidance and anti-evasion rules irrespective of the Agreement; denies treaty benefits where obtaining those benefits was the main purpose or one of the main purposes of the resident's arrangements; and covers legal entities that do not have bona fide business activities.
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