aeat.application.modelo._m210_convenio_lob_advisory module¶
Convenio doble imposición limitation-of-benefits advisory for M210 verification.
A bilateral double-taxation treaty (CDI) rate override is only available to a
filer who actually satisfies the treaty’s residence and beneficial-ownership
conditions; several CDIs bundled in this project’s corpus (see e.g. the
Spain-Germany art. 11 exemption, convenio-es-de-2011:art-11, which
conditions source-state exemption on the recipient being the “beneficiario
efectivo” of the interest) restrict the benefit to a genuine beneficial owner,
and the wider OECD Model Convention limitation-of-benefits (LOB) concept
further restricts treaty relief for entities lacking economic substance in
their state of residence. The engine has no way to verify beneficial ownership
or substance from a filer-supplied country_of_fiscal_residence alone, so
whenever a Convenio override is actually applied to a Modelo 210 rate this
module surfaces a non-blocking ModeloVerificationFinding telling the
operator to confirm LOB eligibility against the specific treaty text — never
silently trusting the residence declaration (no-silent-under-declaration).
The advisory is derived from the RegistrySnapshot
carrying the cross-cutting ConvenioAuthority
projection and the filer’s TaxpayerProfile
country_of_fiscal_residence.
See also
resolve_m210_rate()Application-layer replay of the same tipo-de-gravamen resolution path; this advisory reads the same
ConvenioAuthorityprojection to detect whether an override actually matched._collect_revision_verification_findings()Verification collector that appends this advisory beside the DT 12ª / art. 20 / art. 52 advisories using the same non-blocking mechanism.
ConvenioAuthorityCross-cutting treaty-override authority whose
resolvelookup this advisory consults to detect a matched treaty row.