Article 28 - Miscellaneous Rules - Hong Kong

ARTICLE 28 MISCELLANEOUS RULES 1. The provisions of this Agreement shall in no case prevent a Contracting Party 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 Contracting Party is not required to grant benefits under the Agreement if the main purpose or one of the main purposes of any persons concerned is for the non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in the Agreement for the indirect benefit of residents of third jurisdictions). 3. Cases of legal entities not having bona fide business activities shall also be covered by the provisions of this Article.