Limitation of Benefits
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....tricting, in any manner, 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 a....
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....y the Agreement, if: 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 th....


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