Limitation of benefits: treaty benefits denied where the main purpose of an entity or transaction is to obtain them.

Limitation of benefits preserves domestic anti avoidance measures and denies treaty relief where the main purpose of creating a resident or undertaking a transaction is to obtain treaty benefits. The provision covers legal entities without bona fide business activities. If benefits are denied under this Article, the competent authority of the State applying the denial shall notify the competent authority of the other Contracting State.

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