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<h1>Limitation of benefits: treaty advantages denied where arrangements chiefly aim to obtain benefits or lack genuine business activity.</h1> A resident of a Contracting State shall not be entitled to the benefits of the Agreement if its affairs were arranged so that obtaining the Agreement's advantages was the main purpose or one of the main purposes; this covers legal entities that do not have bona fide business activities and such entities may be denied treaty benefits on that basis.
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