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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 of Benefits

The benefits of this agreement shall not be available to an investor who establishes a legal entity in either Contracting State for the sole purpose of getting the benefits of this Agreement without having a bona fide business activity or to such companies that are directly or indirectly controlled by a third person who is not a resident of either Contracting State, if such benefits would not otherwise be available to that person.