Article 2 of the Protocol also includes a provision (paragraph 4) authorizing the…

U.S. Income Tax Treaty — Italy Technical Explanation - 1984 · 2026-10-03 edition · updated 2026-10-04 · United States

authority of a Contracting State to grant benefits. While an analysis under paragraph 4 may well differ from that under one of the other tests of Article 2 of the Protocol, its objective is the same: to identify investors whose residence in the other State can be justified by factors other than a purpose to derive treaty benefits.

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▸Contents — U.S. Income Tax Treaty — Italy Technical Explanation - 1984

U.S. Income Tax Treaty — Italy Technical Explanation - 1984

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