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 provisions of any other Article of this Agreement, a resident of a Contracting State shall not receive the benefit of any reduction in or exemption from tax provided for in this Agreement by the other a Contracting State if the main purpose or one of the main purposes of such resident or a person connected with such resident was to obtain the benefits of the Agreement.
(2) This Agreement shall not prevent a Contracting State from applying its domestic law on the prevention of tax evasion or tax avoidance.
(3) The benefits under this Agreement shall not be granted to a person who is not the beneficial owner of the item of income.