Article 28 - Limitation of benefits - Mozambique

ARTICLE 28 LIMITATION OF BENEFITS Notwithstanding the provisions of any other Article of this Agreement, a resident of a Contracting State shall not be entitled to the benefits of this Agreement, if its affairs were arranged in such a manner as if it was the primary purpose or one of the primary purposes was to take the benefits of this Agreement. The case of legal entities not having bona fide business activities shall be covered by the provisions of this Article.