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 ... Summary
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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