Limitation of benefit: treaty relief denied where beneficial owner absent or main purpose treaty abuse and domestic rules apply.

Article 28B permits domestic anti abuse rules to be applied to treaty treatment, requires that benefits not be granted to persons who are not the beneficial owner of income, preserves application of domestic Controlled Foreign Corporation rules, and denies treaty benefits where the creation, existence or transactions of a resident had as their main purpose or one of their main purposes the obtaining of treaty benefits not otherwise available.

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