Article 28A - Limitation of Benefits - Kazakhstan (Kazakstan)

1 [ARTICLE 28A LIMITATION OF BENEFITS 1. The provisions of this Convention shall in no case prevent a Contracting State from the application of the provisions of its domestic law and measures against 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 Convention 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 Convention. 3. The benefits under this Convention shall not be granted to a person, which is not the beneficial owner of the items of income derived from the other Contracting State or of the items of capital situated therein. ] ***************** NOTES:- 1 . Inserted vide Notification No. 20/2018 dated 12-04-2018 w.r.e.f.12-03-2018.