This flowchart covers the limitation on benefits ("LOB") provisions included in Article 23 of the Ireland-U.S. Income Tax Treaty. The limitation on benefits provisions are intended to prevent treaty shopping.
The flowchart includes the various types of qualified persons and includes the Publicly Traded Test, the Derivative Benefits Test, the Ownership / Base Erosion Test, the Active Business Test, etc.
Flowcharts are automatically emailed as PDF files to purchasers. If you have not received an email within one hour of your purchase, please Email Us.