Persons qualifying for treaty benefits

The granting of treaty benefits can be a fraught issue for many countries. Treaties are often regarded as an important part of a country’s international tax policy and an important tool in attracting foreign investment, yet there is also a concern that treaties can be exploited by taxpayers to obtain benefits which were not intended by the countries concluding the treaty and which do not have any policy justification behind them. Assessing the relative weight of these two concerns can be a difficult balancing act for countries. This chapter aims to assist the tax administrations that have to determine whether or not to grant treaty benefits in specific cases by shedding some light on the policy and technical issues that arise in this respect.

Sustainable Development Goals:

Peace, Justice and Strong Institutions