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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Miscellaneous Rules

The provisions of this Agreement shall in no case prevent either Contracting State from the application of the provisions of its domestic laws aimed at the prevention of fiscal evasion, in particular, but not limited to, the provisions on thin capitalisation, transfer pricing, substance over form and aggregation of activities carried on by associated enterprises.