Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

Flowchart of LOB Article of Chile-U.S. Income Tax Treaty


Today our sister website,, published a flowchart that deals with the limitation on benefits ("LOB") provisions included in Article 24 of the Chile-U.S. Income Tax Treaty.  Although the treaty has been signed, it has not yet been ratified and is not yet in force.

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 Ownership / Base Erosion Test, the HQ company test, the Active Business Test, Triangular Cases, etc.

The flowchart can be purchased on

Tags: 894 Limitation on Benefits, Charts - Flowcharts