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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.


Application of the Agreement in Special Cases

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, including the provisions regarding thin capitalization and preferential tax regimes.

If the foregoing provision results in double taxation, the competent authorities shall consult each other pursuant to paragraph (3) of Article 25 on how to avoid double taxation.