Limitation of Benefits: treaty entitlement denied where arrangements aim to secure benefits or where beneficial ownership is absent. Article 28A preserves a Contracting State's right to apply its domestic law and anti avoidance measures; denies treaty benefits to residents whose affairs ... Summary
Limitation of Benefits: treaty entitlement denied where arrangements aim to secure benefits or where beneficial ownership is absent.
Article 28A preserves a Contracting State's right to apply its domestic law and anti avoidance measures; denies treaty benefits to residents whose affairs are arranged with the main purpose of obtaining Convention benefits; and withholds benefits from persons who are not the beneficial owner of income or capital derived from the other Contracting State.
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