Limitation of benefits restricts treaty advantages to prevent arrangements whose main purpose is tax benefits. The Amending Protocol revises capital gains taxation to allow a State to tax gains from alienation of shares or interests deriving over fifty percent of value from immovable property situated in that State; replaces Article 27 to expand exchange of foreseeably relevant information with confidentiality limits and an obligation to obtain requested information even without domestic interest; and inserts Article 27A to deny treaty benefits where the main purpose is obtaining those benefits and to require beneficial ownership for benefit entitlement.