Limitation on Benefits Provisions in Tax TreatiesPhilip R. West
Keywords: 国际税收协定,利益限制条款,择协避税,BEPS,tax treaty,Limitation on Benefits provisions,treaty shopping,BEPS Full-Text Cite this paper Add to My Lib Abstract: 摘要 在国际税收协定中,利益限制条款是为了防止非居民纳税人通过择协避税获取本不应当得到的税收协定优惠而设置的、用来评估纳税人资格...
Policy Forum: What Makes a Dutch Company Dutch? The Evolution of US Limitation-on-Benefits Provisions Canadian Tax Journal / Revue Fiscale CanadienneBrown, Patricia A.
Define Limitation on Benefits. means the statutory limitation on the maximum benefit that may be payable to participants under a Pension Plan due to the application of certain provisions contained in the Code.
___ meets all provisions of the Treaty that are necessary to claim a reduced rate of withholding, including any limitation on benefits provisions, and derives the U.S. source income within the meaning of section 894 of the Code, and the regulations thereunder, as the beneficial owner. Signa...
aBut at least when that happened, they could pick up and move. 但,至少当那发生了,他们可能整理和移动。[translate] aapplicable, meets the requirements of the treaty provision dealing with limitation on benefits (see instructions). 可适用,在好处符合应付局限的条约供应的要求 (看指示)。[translate]...
U.S. income tax treaties generally include rules that limit the benefits of the treaties to prevent treaty shopping. These rules are typically called "limitation on benefits" or "LOB" provisions. The U.S. Model Income Tax Treaty describes the starting point of the U.S. in its negotiations...
When Tax Treaty Derivative Benefits Provisions Don't Apply double taxationequivalent beneficiaryThis article discusses tax treaty limitation on benefits (LOB) clauses, with special emphasis on derivative benefits and "... Ruth Mason - 《Social Science Electronic Publishing》 被引量: 3发表: 0年 INTE...
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Share on Facebook limitation (redirected fromlimitation periods) Dictionary Thesaurus Legal Encyclopedia Related to limitation periods:statute of limitations limitation [lim″ĭ-ta´shun] 1.a restriction on an individual's activities. 2.(in plural) factors in a research study that may decrease the...