Article 27 - Limitation of Benefits - Bhutan

ARTICLE 27 LIMITATION OF BENEFITS 1. The provisions of this agreement shall in no case prevent a Contracting State from the application of the provisions of its domestic law and measures concerning tax avoidance or evasion, whether or not described as such. 2. 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 main purpose or one of the main purposes to take the benefits of this Agreement. 3. The case of legal entities not having bona-fide business activities shall be covered by the provisions of this Article.