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
Notwithstanding the provisions of any other Article of this Agreement, a resident of a Contracting State shall not be entitled to the benefits of this Agreement, if its affairs were arranged in such a manner as if it was the primary purpose or one of the primary purposes was to take the benefits of this Agreement. The case of legal entities not having bonafide business activities shall be covered by the provisions of this Article.