Limitation of benefits denies treaty relief when arrangements aim primarily to secure tax treaty advantages or lack genuine business activity. Limitation of Benefits permits a Contracting State to apply domestic anti-avoidance measures despite the Agreement; denies treaty benefits where arrangements have as a main purpose obtaining treaty benefits; and excludes persons or entities not carrying on bona fide business activities from entitlement to treaty benefits.
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 relief when arrangements aim primarily to secure tax treaty advantages or lack genuine business activity.
Limitation of Benefits permits a Contracting State to apply domestic anti-avoidance measures despite the Agreement; denies treaty benefits where arrangements have as a main purpose obtaining treaty benefits; and excludes persons or entities not carrying on bona fide business activities from entitlement to treaty benefits.
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