Article 28A - LIMITATION OF BENEFITS - Poland

1 [ARTICLE 28A LIMITATION OF BENEFITS Benefits of this Agreement shall not be available (a) to a resident (not being an individual) of a Contracting State if the main purpose or one of the main purposes of the creation or existence of such a resident; or (b) with respect to any arrangement or transaction undertaken by a resident of a Contracting State, if the main purpose or one of the main purposes of the creation or existence of such an arrangement or transaction, was to obtain the benefits under this Agreement. ----------------------- NOTES:- 1 . Substituted vide Notification No. 47/2014 dated 24 September, 2014