article 22 (limitation on benefits)

Limitation on Benefits (Background) • Article 22 contains anti-treaty-shopping provisions that are intended to prevent residents of third countries from benefiting  

The Limitation of Benefits (“LOB”) Article, found in Section XXIX-A of the Treaty defines who can sign the Treaty Statement Certification of the Treaty Statement indicates that the recipient of U S source income meets the definition of “qualifying person” as set forth in Article XXIX-A of the Treaty

The lIMITATIon-on-benefITS ArTIcle In The fIfTh ProTocol 25:3 paid to US derivative benefits provisions of the lOb article in the particular treaty For ex- ample 

Therefore, to prevent such treaty shopping, both countries renegotiated the treaty and included the LOB clause w e f 1st April 2017 “Article 27A – LIMITATION OF  

The freedom of establishment is guaranteed in Article 52 EC TREATY art 52 4Hereinafter European Union, EU, or Community sAs used in this comment, " 

Explanation of the Limitation of Benefits Article and Treaty Statement The Internal Revenue Service of the United States of America recently adopted new 

the Limitation on Benefits Article Treaties By Michael J Miller Accessing U S Income Tax Treaties: Current Trends in the Limitation on Benefits Article As U S  

described in subparagraph a) of paragraph 3 of Article 11 (Application of Tax provisions of that paragraph, the Simplified Limitation on Benefits Provision shall