Limitation of benefits: treaty relief can be denied where the main purpose is obtaining treaty advantages. The Limitation of Benefits clause preserves a Contracting State's ability to apply its domestic anti-avoidance measures to deny treaty relief; residents are ineligible for benefits if their affairs were arranged with the main purpose of obtaining treaty advantages, and legal entities without bona fide business activities are specifically within its scope.
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 can be denied where the main purpose is obtaining treaty advantages.
The Limitation of Benefits clause preserves a Contracting State's ability to apply its domestic anti-avoidance measures to deny treaty relief; residents are ineligible for benefits if their affairs were arranged with the main purpose of obtaining treaty advantages, and legal entities without bona fide business activities are specifically within its scope.
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