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All glossary terms

Glossary term

Limitation on Benefits (LOB)

A treaty provision restricting treaty benefits to residents meeting objective qualification tests.

Related terms

1

Jurisdictions

us, global

Definition

LOB articles in U.S. treaties (and post-MLI treaties of other countries) prevent treaty shopping by requiring residents to meet ownership, derivative-benefits, public-trading, or active-trade-or-business tests.

Examples

  • A holding company in a treaty jurisdiction must satisfy ownership and base-erosion tests to claim treaty benefits.

Related terms

Translations

ESlimitación de beneficios
ZH利益限制条款
DELimitation-on-Benefits
FRlimitation des bénéfices
JA特典制限条項

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