https://www.taxtmi.com/acts?id=15017 The provision denies treaty benefits to a resident whose affairs were arranged so that the primary purpose was to obtain those benefits; legal entities lacking bona fide business activities are explicitly covered. It operates notwithstanding other treaty articles and serves to prevent treaty shopping by conditioning entitlement to benefits on substantive commercial activity and absence of primary intent to secure treaty advantages. en-us Tue, 30 Aug 2011 12:33:51 +0530 Sat, 24 Aug 2024 11:21:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15017 The provision denies treaty benefits to a resident whose affairs were arranged so that the primary purpose was to obtain those benefits; legal entities lacking bona fide business activities are explicitly covered. It operates notwithstanding other treaty articles and serves to prevent treaty shopping by conditioning entitlement to benefits on substantive commercial activity and absence of primary intent to secure treaty advantages. Act-Rules DTAA Tue, 30 Aug 2011 12:33:51 +0530 https://www.taxtmi.com/acts?id=15017