Limitation of benefits denies treaty relief where arrangements aim to obtain benefits or where shell companies lack substantive operations. Limitation of Benefits denies benefits where a resident's affairs are arranged with the primary purpose of obtaining treaty advantages. A shell/conduit ... Summary
Limitation of benefits denies treaty relief where arrangements aim to obtain benefits or where shell companies lack substantive operations.
Limitation of Benefits denies benefits where a resident's affairs are arranged with the primary purpose of obtaining treaty advantages. A shell/conduit company-defined by negligible or no real and continuous business activities-is ineligible. A resident is deemed a shell/conduit company if its operational expenditure in the relevant contracting State in the twelve months preceding the gain falls below a specified threshold, and is deemed not to be one if listed on a recognized stock exchange or if expenditure meets or exceeds that threshold.
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