Limitation of Benefits restricts treaty benefits where domestic anti avoidance applies or arrangements aim chiefly to secure treaty advantages. Limitation of Benefits preserves a Contracting State's right to apply domestic anti-avoidance and anti-evasion laws, denies treaty benefits where arrangements have as their main purpose obtaining those benefits, and covers legal entities lacking bona fide business activities so that benefits may be refused where entities lack genuine commercial substance.
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 restricts treaty benefits where domestic anti avoidance applies or arrangements aim chiefly to secure treaty advantages.
Limitation of Benefits preserves a Contracting State's right to apply domestic anti-avoidance and anti-evasion laws, denies treaty benefits where arrangements have as their main purpose obtaining those benefits, and covers legal entities lacking bona fide business activities so that benefits may be refused where entities lack genuine commercial substance.
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