On 25 January 2012, the Ministry of Finance published official guidance (IV B 3 – S 2411/07/10016) on the application of the anti-treaty-shopping rules embodied in article 50d(3) of the Income Tax Act as amended in 2011.
Under the revised rules, treaty benefits to a non-resident (intermediate) company are denied if:
| - | as far as its shareholders would not be entitled to the treaty benefits if they would ha… |