Treaty-shopping safeguards restrict treaty benefits to prevent non-taxation or reduced taxation and indirect benefits to third-country residents. Amendment conditions treaty relief on absence of arrangements creating opportunities for non-taxation or reduced taxation, including treaty-shopping arrangements aimed at obtaining reliefs for the indirect benefit of residents of any other country or territory, by inserting qualifying words into clause (b) of subsection (1) of section 90A of the Income-tax Act.
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.
Treaty-shopping safeguards restrict treaty benefits to prevent non-taxation or reduced taxation and indirect benefits to third-country residents.
Amendment conditions treaty relief on absence of arrangements creating opportunities for non-taxation or reduced taxation, including treaty-shopping arrangements aimed at obtaining reliefs for the indirect benefit of residents of any other country or territory, by inserting qualifying words into clause (b) of subsection (1) of section 90A of the Income-tax Act.
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