When Tax Treaty Derivative Benefits Provisions Don't Apply

Mason, Ruth

When Tax Treaty Derivative Benefits Provisions Don't Apply

Tax Notes International, Vol. 43, p. 563, August 14, 2006 (extended reprint of article appearing in Tax Notes, Vol. 112, p. 367, 2006)

6 Pages Posted: 15 Jul 2006 Last revised: 29 Aug 2008

See all articles by Ruth Mason

Ruth Mason

University of Virginia School of Law

Abstract

This article discusses tax treaty limitation on benefits (LOB) clauses, with special emphasis on derivative benefits and "equivalent beneficiaries."

Keywords: tax treaties, derivative benefits, limitation on benefits, withholding taxes, double taxation, equivalent beneficiary

JEL Classification: H20, H26, K34, N40

Suggested Citation: Suggested Citation

Mason, Ruth, When Tax Treaty Derivative Benefits Provisions Don't Apply. Tax Notes International, Vol. 43, p. 563, August 14, 2006 (extended reprint of article appearing in Tax Notes, Vol. 112, p. 367, 2006), Available at SSRN: https://ssrn.com/abstract=914601