https://www.taxtmi.com/manuals?id=4515 Limitation on Benefit clauses are targeted anti treaty shopping measures that condition entitlement to tax treaty benefits for non individuals on objective tests. Common tests include an ownership test requiring qualifying resident or national beneficial ownership, a base erosion test preventing substantial payments to non qualified persons, an active business test excluding passive investment activities, and a recognized stock exchange test for regularly traded companies. Treaties typically set the precise formulation and may permit competent authority relief; inclusion of LoB clauses in Indian treaties responds to the absence of an inherent anti abuse rule. en-us Fri, 01 Mar 2024 18:05:00 +0530 Wed, 14 Aug 2024 10:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4515 Limitation on Benefit clauses are targeted anti treaty shopping measures that condition entitlement to tax treaty benefits for non individuals on objective tests. Common tests include an ownership test requiring qualifying resident or national beneficial ownership, a base erosion test preventing substantial payments to non qualified persons, an active business test excluding passive investment activities, and a recognized stock exchange test for regularly traded companies. Treaties typically set the precise formulation and may permit competent authority relief; inclusion of LoB clauses in Indian treaties responds to the absence of an inherent anti abuse rule. Manuals Income Tax Fri, 01 Mar 2024 18:05:00 +0530 https://www.taxtmi.com/manuals?id=4515