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 on Benefits
(1) This Agreement shall not be interpreted to mean that a Contracting State is prevented from applying its domestic legal provisions on the prevention of tax evasion or tax avoidance. If the foregoing provision results in double taxation, the competent authorities shall consult each other pursuant to paragraph (3) of Article 24 on how to avoid double taxation.
(2) The benefits of this Agreement should not be available where a main purpose for entering into certain transactions or arrangements was to secure a more favorable tax position and obtaining that more favourable treatment in these circumstances would be contrary to the object and purpose of the relevant provisions.