Denial of treaty benefits where an enterprise was created mainly to obtain convention benefits, preserving domestic anti evasion rules. The Convention preserves domestic measures to prevent tax evasion and provides that an enterprise shall be denied treaty benefits if its creation was ... Summary
Denial of treaty benefits where an enterprise was created mainly to obtain convention benefits, preserving domestic anti evasion rules.
The Convention preserves domestic measures to prevent tax evasion and provides that an enterprise shall be denied treaty benefits if its creation was mainly to obtain Convention advantages; this rule expressly applies to legal entities that do not carry on bona fide business activities, allowing exclusion of entities formed as artificial conduits.
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