Limitation of benefits denies treaty advantages where the main purpose is obtaining treaty relief, preserving domestic anti evasion rules. Limitation of Benefits restricts treaty relief when the main purpose of creating a resident or undertaking a transaction is to obtain Agreement benefits; domestic provisions to prevent tax evasion remain applicable. Benefits are denied where one main purpose is to secure advantages under the Agreement, and the rule explicitly covers legal entities not having 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.
Limitation of benefits denies treaty advantages where the main purpose is obtaining treaty relief, preserving domestic anti evasion rules.
Limitation of Benefits restricts treaty relief when the main purpose of creating a resident or undertaking a transaction is to obtain Agreement benefits; domestic provisions to prevent tax evasion remain applicable. Benefits are denied where one main purpose is to secure advantages under the Agreement, and the rule explicitly covers legal entities not having bona fide business activities.
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