Simplified Limitation on Benefits restricts treaty benefits to qualified persons with exceptions and competent authority relief. Article 27 preserves diplomatic and consular fiscal privileges while applying the MLI's anti-abuse rules: the Simplified Limitation on Benefits confines treaty benefits to qualified persons or to residents engaged in the active conduct of a business (with specified exclusions), allows ownership-based and equivalent beneficiary tests, treats activities of connected persons as those of the resident, and authorises competent authority relief based on object and purpose considerations.
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.
Simplified Limitation on Benefits restricts treaty benefits to qualified persons with exceptions and competent authority relief.
Article 27 preserves diplomatic and consular fiscal privileges while applying the MLI's anti-abuse rules: the Simplified Limitation on Benefits confines treaty benefits to qualified persons or to residents engaged in the active conduct of a business (with specified exclusions), allows ownership-based and equivalent beneficiary tests, treats activities of connected persons as those of the resident, and authorises competent authority relief based on object and purpose considerations.
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