Article 27A - Limitation of Benefits - Israel

1 [Article 27A LIMITATION OF BENEFITS 1. Benefits of this Convention shall not be available to a resident of a Contracting State, or with respect to any transaction undertaken by such resident, if the main purpose or one of the main purposes of the creation or existence of such resident or of the transaction undertaken by it, was to obtain benefits under this Convention that would not otherwise be available. 2. The Convention shall not prevent a Contracting State from applying its domestic law on prevention of tax evasion or tax avoidance. 3. Any benefit under this Convention shall not be granted to a person who is not the beneficial owner of the item of income. ] ********* NOTES:- 1. Inserted vide NOTIFICATION NO. 10/2017 dated 14-02-2017