Limitation of benefits: treaty relief denied where the main purpose is to obtain tax treaty benefits. Article 27A denies treaty benefits where the main purpose, or one of the main purposes, of creating or using a resident or of a transaction was to obtain Convention benefits that would not otherwise be available; it permits a Contracting State to apply domestic anti evasion or anti avoidance law and prohibits granting any benefit to a person who is not the beneficial owner of the income.