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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.


Limitation of Benefits

(1) Benefits of this Agreement shall not be available to a resident of a Contracting State, or with respect to any transaction undertaken by such a resident, if the main purpose of creation or existence of such a resident or of the transaction undertaken by him, was to obtain the benefits under this Agreement that would not otherwise be available.

(2) Where by reason of the provisions of paragraph (1) resident of a Contracting State is denied the benefit of this Agreement in the other Contracting State, the competent authority of the other Contracting State denying the benefits shall notify the competent authority of the first-mentioned State.