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Limitation of Benefits
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....thstanding any provisions of [the Agreement], a benefit under [the Agreement] shall not be granted in respect of an item of income or capital if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of [the Agreement]. The following paragraphs 8 to 13 of Article 7 of the MLI applies and supersedes the provisions of this Agreement: ARTICLE 7 OF THE MLI - PREVENTION OF TREATY ABUSE (Simplified Li....
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....er the taxation laws of that [Contracting State] and: A) that is established and operated exclusively or almost exclusively to administer or provide retirement benefits and ancillary or incidental benefits to individuals and that is regulated as such by that [Contracting State] or one of its political subdivisions or local authorities; or B) that is established and operated exclusively or almost exclusively to invest funds for the benefit of entities or arrangements referred to in subdivision A); e) a person other than an individual, if, on at least half the days of a twelve-month period that includes the time when the benefit would otherwise be accorded, persons who are residents of that [Contracting State] and t....
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....d in subparagraph a) shall be considered to be satisfied with respect to such item only if the business activity carried on by the resident in the first-mentioned [Contracting State] to which the item is related is substantial in relation to the same activity or a complementary business activity carried on by the resident or such connected person in the other [Contracting State]. Whether a business activity is substantial for the purposes of this subparagraph shall be determined based on all the facts and circumstances. c) For purposes of applying this paragraph, activities conducted by connected persons with respect to a resident of a [Contracting State] shall be deemed to be conducted by such resident. Paragraph 11 of Article ....
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....ntracting State]. Paragraph 13 of Article 7 of the MLI For the purposes of the Simplified Limitation on Benefits Provision: a) the term "recognised stock exchange" means: i) any stock exchange established and regulated as such under the laws of either [Contracting State]; and ii) any other stock exchange agreed upon by the competent authorities of the [Contracting States]; b) the term "principal class of shares" means the class or classes of shares of a company which represents the majority of the aggregate vote and value of the company or the class or classes of beneficial interests of an entity which represents in the aggregate a majority of the aggregate vote and value of the entity; c) ....