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 28
Limitation of Benefits
(1) The competent authorities upon their mutual agreement, may deny the benefits of this Agreement to a resident of a Contracting State, or with respect to any transaction undertaken by such a resident, if in their opinion the main purpose of the 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) The competent authorities of the Contracting States may consult together with a view to develop a commonly agreed application of the provisions of this Article.