Limitation of benefits

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..... cting State if the main purpose or one of the main purposes of the creation or existence of such resident or any person connected with such resident is to obtain the benefits under this Agreement that would not otherwise be available. 2. Without prejudice to the generality of paragraph 1, the following shall be the circumstances where the main purpose or one of the main purposes for the creation .....

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..... t be entitled to the benefits of the Agreement if more than 50% of the person's gross income for the taxable year is paid or payable to persons who are not residents of either of the Contracting States in the form of payments that are deductible for the computation of taxes in the person's State of residence. 3. The above-mentioned provisions, however, will not apply if the person activel .....

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