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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.


Right to Benefits of the Convention

(1) This Convention may not be construed as preventing a Contracting State from applying its internal law concerning the prevention of fiscal fraud or evasion, in so far as such application does not give rise to a taxation contrary to this Convention.

(2) Notwithstanding the other provisions of this Convention, no benefit under this Article shall be granted in respect of an item of income or capital if it may be reasonably concluded, having regard to all facts and circumstances specific to the situation, that the granting of this benefit was one of the major goals of an arrangement or transaction that allowed, directly or indirectly, to obtain it, unless it is established that the granting of this benefit in these circumstances would be consistent with the object and purpose of the relevant provisions in this Convention.