The Resource Limitation on benefits

Limitation on benefits

Label
Limitation on benefits
Title
Limitation on benefits
Creator
Subject
Summary
Explains the background for including a provision on limitation on benefits (LOB) in a tax treaty, namely as a means of preventing treaty shopping. The two main issues in respect of LOB-provisions are discussed, i.e. interpretation of undefined terms and the effect on persons not resident in either contracting state. Article 26 of the 1992 treaty between the Netherlands and the United States is discussed, including its significance for companies resident in Denmark. An overview of provisions of Danish tax treaties that contain a provision similar in type to a LOB-provision is given. It is concluded that a comprehensive LOB-provision containing definitions of its terms offers a taxpayer more protection than a simple LOB-provision containing undefined terms
Citation source
In: Skat Udland. - (1997),
http://library.link/vocab/creatorName
Andersen, P.S
Language note
Danish
http://library.link/vocab/subjectName
  • treaty interpretation
  • treaty shopping
  • LoB
  • anti-avoidance
Label
Limitation on benefits
Instantiates
Publication
Abbreviated title
SU
Label
Limitation on benefits
Publication
Abbreviated title
SU

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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