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<h1>Limitation of Benefits in UK DTAA: Article 28C Denies Benefits for Tax Avoidance-Driven Entities</h1> Article 28C of the Double Taxation Avoidance Agreement (DTAA) between the UK and another Contracting State outlines a Limitation of Benefits provision. It specifies that benefits under the Convention are not available to residents of a Contracting State if the primary or one of the main purposes of their creation or transactions is to obtain Convention benefits. If a resident is denied benefits, the competent authority of the denying State must inform the competent authority of the resident's State. This provision was inserted by Notification No. 10/2014, effective from December 27, 2013.