Article 29 - Limitation of Benefits - UAE (United Arab Emirates)

ARTICLE 29 LIMITATION OF BENEFITS [REPLACED by paragraph 1 of Article 7 of the MLI] [An entity which is a resident of a Contracting State shall not be entitled to the benefits of this Agreement if the main purpose or one of the main purposes of the creation of such entity was to obtain the benefits of this Agreement that would not be otherwise available. The cases of legal entities not having bonafide business activities shall be covered by this Article.] The following paragraph 1 of Article 7 of the MLI replaces Article 29 of this Agreement: ARTICLE 7 OF THE MLI PREVENTION OF TREATY ABUSE (Principal purposes test provision) Notwithstanding any provisions of the Agreement, a benefit under the Agreement shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the Agreement.