Article 27 - Limitation Of Benefits - Malta

ARTICLE 27 LIMITATION OF BENEFITS 1. Nothing in this Agreement shall affect the application of the domestic provisions to prevent tax evasion. 2. Benefits of this Agreement shall not be available to a resident of a Contracting State, or with respect to any transaction undertaken by such a resident, if the main purpose or one of the main purposes of the creation or existence of such a resident or of the transaction undertaken by him, was to obtain benefits under this Agreement that would not otherwise be available. 3. The case of legal entities not having bona fide business activities shall be covered by the provisions of this Article.