Limitation of benefits: domestic anti avoidance rules may be applied despite treaty protections under the agreement. Article 27 provides that limitation of benefits does not prevent a Contracting State from applying its domestic law and measures concerning tax avoidance ... Summary
Limitation of benefits: domestic anti avoidance rules may be applied despite treaty protections under the agreement.
Article 27 provides that limitation of benefits does not prevent a Contracting State from applying its domestic law and measures concerning tax avoidance or evasion, whether or not described as such, thereby preserving the State's ability to enforce internal anti avoidance and anti evasion rules alongside the treaty.
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