Limitation of benefits: treaty benefits denied where arrangements primarily aim to secure treaty advantages or lack bona fide business. The Agreement preserves a Contracting State's domestic anti-avoidance and anti-evasion measures; denies treaty benefits where a resident's affairs were ... Summary
Limitation of benefits: treaty benefits denied where arrangements primarily aim to secure treaty advantages or lack bona fide business.
The Agreement preserves a Contracting State's domestic anti-avoidance and anti-evasion measures; denies treaty benefits where a resident's affairs were arranged with the main purpose of obtaining those benefits; and denies benefits to any person, including legal entities, that do not have bonafide business activities.
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