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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.


Limitations on Benefits

(1) Benefits provided under this Agreement shall not be granted to companies of either Contracting State if the purpose of the establishment of such companies was solely to obtain benefits under this Agreement that would not otherwise be available.

(2) The provisions of this Agreement shall in no case prevent either Contracting State from the application of the provisions of its domestic laws aiming at the prevention of fiscal evasion, in particular the provisions on thin capitalisation, transfer pricing, etc.