Double taxation treaty scope: Convention applies to residents and limits benefits subject to anti-abuse conditions. The Convention applies to persons who are residents of one or both Contracting States, preserves domestic-law and other-agreement benefits, directs that disputes over whether a taxation measure falls within the Convention be resolved through the Mutual Agreement Procedure, treats income through fiscally transparent entities as income of the resident to the extent taxed as such, limits relief where tax is based on remitted amounts, and conditions treaty benefits to prevent treaty-shopping and low-tax structures while allowing competent-authority exceptions.
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.
Double taxation treaty scope: Convention applies to residents and limits benefits subject to anti-abuse conditions.
The Convention applies to persons who are residents of one or both Contracting States, preserves domestic-law and other-agreement benefits, directs that disputes over whether a taxation measure falls within the Convention be resolved through the Mutual Agreement Procedure, treats income through fiscally transparent entities as income of the resident to the extent taxed as such, limits relief where tax is based on remitted amounts, and conditions treaty benefits to prevent treaty-shopping and low-tax structures while allowing competent-authority exceptions.
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