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
Citations
Related citations
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TermTreaty Shopping
Cited by
Primary sources
- IRS Treaty ManualVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.