December 16, 2022
Ecovis Americas published an article by International Tax Senior Manager Abhishek Gupta, about the imperative to meet the requirements of the Limitation on Benefits articles.
Ecovis Americas
By Abhishek Gupta, Senior, International Tax Services
Excerpt:
The LoB article is an anti-treaty-shopping provision to prevent residents of third countries from obtaining benefits under a tax treaty. To obtain these lower withholding rates, one of the provisions of the LoB test must be met.