Limitation of benefits bars treaty relief where arrangements are primarily for obtaining tax treaty advantages. A resident of a Contracting State is denied the Agreement's benefits when its affairs are arranged with the primary purpose of obtaining those benefits; ... Summary
Limitation of benefits bars treaty relief where arrangements are primarily for obtaining tax treaty advantages.
A resident of a Contracting State is denied the Agreement's benefits when its affairs are arranged with the primary purpose of obtaining those benefits; legal entities lacking bona fide business activities are covered and excluded from entitlement to treaty relief.
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