Limitation of Benefits

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.... the creation or existence of such a resident or of the transaction undertaken by him, was to obtain benefits under this Convention. 2. Where by reason of this Article a resident of a Contracting State is denied the benefits of this Convention in the other Contracting State, the competent authority of that other Contracting State shall notify the competent authority of the first-mentioned Contr....

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.... 1. India understands that the UK considers that paragraph 1 of Article 7 of the MLI replaces Article 28C and supersedes paragraph 6 of Article 11, paragraph 11 of Article 12 and paragraph 9 of Article 13 of the Convention and accordingly in its version of synthesised text makes such reference to paragraph 1 of Article 7 of the MLI in relation to those paragraphs of the Convention and places....