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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 28

Limitation of Benefits

(1) Notwithstanding the other provisions of this Convention, a person that is a resident of a Contracting State shall not be entitled to tax reductions or exemptions granted by the other Contracting State under this Convention if the main purpose or one of the main purposes of the establishment or existence of such resident, or of any person concerned with such resident, was to be granted the benefits envisaged by this Convention, to which said person would not otherwise have been entitled.

(2) The application of domestic laws concerning limitation on expenditure and other deductions deriving from transactions between enterprises of a Contracting State and enterprises situated in the other Contracting State shall not be affected by the provisions contained in this Convention.