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Cape Verde - Sao Tome Tax Treaty (2019, not yet in force) — Orbitax Tax Hub

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 29

Entitlement to Benefits of the Convention

(1) The provisions of this Convention shall not be construed as to, in any way, prevent the application by a Contracting State of the anti-abuse provisions of its domestic law.

(2) The benefit provided for in this Convention shall not be granted to a resident of a Contracting State who is not the beneficial owner of income derived in the other Contracting State.

(3) The benefits provided in this Convention shall not be granted in respect of an item of income when if it is reasonable to conclude, having regard of all relevant facts and circumstances, that obtaining that benefit was the main, or one of the main purposes, of any transaction or construction which gave rise directly or indirectly to that benefit, unless it is determined that the granting of such benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Convention.