Common use of Entitlement to treaty benefits Clause in Contracts

Entitlement to treaty benefits. (a) This Agreement shall not be interpreted to mean that a Contracting State is prevented from applying its domestic legal provisions on the prevention of tax evasion or tax avoidance. (b) The Contracting States understand that their domestic rules and procedures with respect to the abuses of law (including tax treaties) may be applied to the treatment of such abuses. (c) This Agreement does not prevent the Contracting States from applying domestic Controlled Foreign Company rules. (d) The provisions of Articles 10, 11 and 12 shall not apply if it was the main purpose of any person concerned with the creation or assignment of shares or other rights in respect of which the dividends are paid, the creation or assignment of the debt-claim in respect of which the interest is paid, the creation or assignment of rights in respect of which the royalties are paid, to take advantage of these Articles by means of that creation or assignment.

Entitlement to treaty benefits. (a) This Agreement shall not be interpreted to mean that a Contracting State is prevented from applying its domestic legal provisions on the prevention of tax evasion or tax avoidance. (b) The Contracting States understand declare that their domestic rules and procedures with respect to the abuses of law (including tax treaties) may be applied to the treatment of such abuses. (cb) This Agreement Convention does not prevent the Contracting States from applying to apply domestic Controlled Foreign Company rules. (dc) The provisions of Articles 10, 11 and 12 shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of shares or other rights in respect of which the dividends are paid, the creation or assignment of the debt-claim in respect of which the interest is paid, the creation or assignment of rights in respect of which the royalties are paid, paid to take advantage of these Articles by means of that creation or assignment. d) It is understood that the benefits under this Convention shall not be granted to a person, which is not the beneficial owner of the items of income derived from the other Contracting State.

Entitlement to treaty benefits. (a) This Agreement Convention shall not be interpreted to mean that a Contracting State is prevented from applying its domestic legal provisions on the prevention of tax evasion or tax avoidance. (b) The Contracting States understand declare that their domestic rules and procedures with respect to the abuses of law (including tax treaties) may be applied to the treatment of such abuses. (c) This Agreement Convention does not prevent the Contracting States from applying to apply domestic Controlled Foreign Company rules. (d) The provisions of Articles 10, 11 and 12 shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of shares or other rights in respect of which the dividends are paid, the creation or assignment of the debt-debt- claim in respect of which the interest is paid, the creation or assignment of rights in respect of which the royalties are paid, paid to take advantage of these Articles by means of that creation or assignment.