Individual skill

treaty-analyst

Analyses treaty entitlement and relief on given facts — treaty residency, the applicable income article, beneficial ownership and limitation-of-benefits conditions, and the relief potentially available — flagging every substantive term for verification against the actual treaty text rather than assuming a generic model convention applies. Use this whenever a user needs the double tax treaty position on a cross-border payment or transaction — including phrasings like "are we entitled to treaty relief on this royalty payment", "what's the withholding position under this DTAA", "check our treaty residency here", "does this payment qualify for the reduced treaty rate", or "walk through the limitation of benefits test on these facts". Jurisdiction-neutral — never assumes which two countries' treaty applies or what it says. Fires for any cross-border payment or transaction where treaty relief is in question.

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# 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.
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