Article 28 - Limitation of benefits - Taipei

ARTICLE 28 LIMITATION OF BENEFITS 1 . Notwithstanding the provisions of any other Article of this Agreement, a resident of a territory shall not be entitled to the benefits of this Agreement if the primary purpose or one of the primary purposes of such resident or a person connected with such resident was to obtain the benefits of this Agreement. 2. The cases of legal entities not having bona fide business activities shall be; covered by the provisions of this Article.