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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) A person that is a resident of a Contracting State and derives income from the other Contracting State shall not be entitled to relief from taxation otherwise provided for in this Convention if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of such item of income to take advantage of the provisions of this Convention.

(2) The provisions of this Convention shall not be applicable to companies which benefit from a special fiscal treatment under the laws or administrative practice of that or of the other Contracting State. Similarly, such provisions shall not be applicable in respect of income which a resident of the other Contracting State receives from such companies, or in respect of shares or other corporate rights in the capital of those companies which are held by such resident.