Limitation of Benefits denies treaty benefits when an entity's principal purpose is to obtain treaty advantages. Limitation of Benefits denies treaty benefits where domestic anti avoidance measures apply or where an enterprise's main purpose was to obtain benefits under the agreement; it covers legal entities not having bona fide business activities and preserves application of domestic laws targeting tax avoidance or evasion.
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 benefits when an entity's principal purpose is to obtain treaty advantages.
Limitation of Benefits denies treaty benefits where domestic anti avoidance measures apply or where an enterprise's main purpose was to obtain benefits under the agreement; it covers legal entities not having bona fide business activities and preserves application of domestic laws targeting tax avoidance or evasion.
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