Limitation of Benefits: treaty relief denied where principal purpose of an entity or transaction is to obtain tax treaty benefits. Benefits under the Poland-DTAA are denied where the main purpose or one of the main purposes of creating or maintaining a resident (other than an individual), or of any arrangement or transaction undertaken by a resident, was to obtain the Agreement's benefits; this implements a purpose-based limitation of benefits and was substituted by Notification No. 47/2014.
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: treaty relief denied where principal purpose of an entity or transaction is to obtain tax treaty benefits.
Benefits under the Poland-DTAA are denied where the main purpose or one of the main purposes of creating or maintaining a resident (other than an individual), or of any arrangement or transaction undertaken by a resident, was to obtain the Agreement's benefits; this implements a purpose-based limitation of benefits and was substituted by Notification No. 47/2014.
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