Treaty shopping uses intermediaries or residence shifts to secure unintended tax treaty benefits through routing and mismatches. Treaty shopping uses intermediary persons or entities to obtain treaty benefits not available directly, through structures such as direct conduits, stepping-stone conduits, triangular arrangements, hybrid entities, or taxpayer emigration to another treaty state. States counter these practices with neutral measures combining domestic and treaty rules, specific denials for entities not subject to tax in their residence, purpose-based anti-abuse provisions, and comprehensive domestic or treaty-based rules like limitation-on-benefits or broad abuse doctrines.
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 uses intermediaries or residence shifts to secure unintended tax treaty benefits through routing and mismatches.
Treaty shopping uses intermediary persons or entities to obtain treaty benefits not available directly, through structures such as direct conduits, stepping-stone conduits, triangular arrangements, hybrid entities, or taxpayer emigration to another treaty state. States counter these practices with neutral measures combining domestic and treaty rules, specific denials for entities not subject to tax in their residence, purpose-based anti-abuse provisions, and comprehensive domestic or treaty-based rules like limitation-on-benefits or broad abuse doctrines.
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