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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.

ARTICLE 26

Limitation on Benefits

(1) Notwithstanding the provisions of any other Article of this Agreement, a resident of a territory shall not receive the benefit of any reduction in or exemption from tax provided for in the Agreement by the other territory if the competent authority of the other territory determines that the main purpose or one of the main purposes of such resident or a person connected with such resident was to obtain the benefits of this Agreement.

(2) The Agreement shall not prevent a territory from applying its domestic laws on the prevention of tax evasion or tax avoidance.