https://www.taxtmi.com/caselaws?id=352251 UAE treaty residence depends on incorporation in the UAE and management and control wholly there, supported by evidence of UAE-based board decisions, management and corporate records. Directors' or shareholders' nationality and the AGM location are not determinative. "Liable to tax" refers to fiscal domicile and the UAE's taxing right based on residence, incorporation or management; actual UAE tax payment is not required, as treaty protection addresses potential as well as current double taxation. The limitation of benefits clause applies only where an entity was created mainly to obtain otherwise unavailable treaty benefits. It cannot deny relief without proof of treaty shopping. en-us Tue, 28 Nov 2017 00:00:00 +0530 Mon, 11 Dec 2017 07:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=352251 UAE treaty residence depends on incorporation in the UAE and management and control wholly there, supported by evidence of UAE-based board decisions, management and corporate records. Directors' or shareholders' nationality and the AGM location are not determinative. "Liable to tax" refers to fiscal domicile and the UAE's taxing right based on residence, incorporation or management; actual UAE tax payment is not required, as treaty protection addresses potential as well as current double taxation. The limitation of benefits clause applies only where an entity was created mainly to obtain otherwise unavailable treaty benefits. It cannot deny relief without proof of treaty shopping. Case-Laws Income Tax Tue, 28 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=352251