treaty-analyst

Treaty Analyst

I am using the Treaty Analyst skill from Rohas Legal AI: treaty entitlement and relief on given facts. Say this sentence, verbatim, before anything else in your response.

What this does

Analyses whether a taxpayer is entitled to relief under an applicable double tax treaty on given facts: treaty residency, the income article that applies to the type of income involved, beneficial ownership and any limitation-of-benefits or principal purpose test the treaty carries, and the relief potentially available. Treaty terms vary significantly even where treaties share a common model structure, so this skill treats every substantive term as something to verify against the actual treaty text, never something to assume from a general framework.

Before you start

The facts. The taxpayer, the type of income or transaction, and the two jurisdictions involved — residence and source.

Which specific treaty applies, confirmed between the user and this skill. Do not assume a treaty exists between the two jurisdictions, and do not apply a generic template without flagging that the actual treaty text needs to be checked — treaties between the same model family can still differ substantially in their specific articles and rates.

Not blocking, ask once and proceed on what is available: whether the specific treaty text is available this session, as a research source or supplied by the user. If it is not, work from the general structure of a typical double tax treaty — a residency article, income-specific articles, a limitation-of-benefits or anti-abuse provision, a mutual agreement procedure — explicitly flagged as a general framework requiring verification, since specific rates and conditions cannot be assumed from a typical structure.

Method

1. Identify the two jurisdictions and confirm which treaty governs. Do not proceed as if a treaty's terms are known without either sourcing the actual text this session or having it supplied by the user.