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.
ARTICLE 26
LIMITATION OF BENEFITS
(1) The competent authority of a territory may deny the benefits of these provisions to any person, or with respect to any transaction, if in its opinion the granting of those benefits would constitute an abuse of these provisions.
(2) These provisions will in no case prevent either territory from applying the provisions of its domestic laws that are aimed at the prevention of fiscal avoidance or evasion.