Limitation of Benefits

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....nner, the application of any provisions of the laws or regulations of a Contracting State which are designed to prevent the avoidance or evasion of taxes, whether or not described as such. 2. No pers....

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....a) the resident is controlled directly or indirectly by one or more persons that are not residents of that Contracting State; or b) the main purpose or one of the main purposes of any person concern....