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where PE is Rls .
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claim or
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right use information
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genuine economic
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involved in order toprevent
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AA 1h5)th6)
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o AA 116)
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if PE BO no otherpart of company to which PE be
-
= -
,
where Rls
company
Bo
longs
-
can be
anymore
-
.
-
PE -
where PE is Rls .
⇒ Source MS oAA.rs#
F. Interest or
Royalty is
only
made
by a PE
, if that pay -
o
PE -
-
Bo , if :
ment is tax deductible the PE in the US
expense for
- -
in which the PE is situated 1) effective connection of PE with debt -
claim or
to
right use information
Benehicialcwnership ↳ link
genuine economic
; pay
m receivedfor benefits
.
payment ?
who is the effective of 1 or 12 of I or R
-
DE and DE debt
payee is attributable to or -
,
claim assets of
right
or to use is part of business
oAA.NU# PE
company BO, if
payments are receivedfor 2) I or R represent income
-
's must respect
payment in
=
company
own -
benefit and not as of which the recipient PE is
intermediary for anotherperson
subject to tax
-
in the MS in which it is situated
I
should prevent circumvention of not benefits
granting I.frand and Abuse
indirectly to companies from third States -
ECT Ctl, if can decide on use of interest AA 511 )
o
Company
-
i .
-
and carries risk of potential losses alone
IRD doesn't application of domestic
preclude
-
or
oAA.to based provisions for prevention of fraud
agreement -
and abuse
IRD t ) in case of abused
fraud
-
a AA 512 )
-
Ct) if chosen corporate structure
-
-
:
aims to exploit certain
information deficits beta States .
involved in order toprevent
-
US have option to withdraw benefits or
refuse apple .
effective taxation at recipients of IRD if principal or one of the principle motives for
the transaction is tax evasion, avoidance or abuse
, B.Repaymentofwtttwithneldatsne.ru
Source state
may oblige payer of Ior R
the to withhold the
-
tax of the
payment , if source tax exemption
requirements
have
not been attested at time of
payment
a later attestation source state has toprovide for reimbursement
-
:
procedure
AA 1h5)th6)
.
