Limitation of Benefits

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..... Article 7 of the MLI] [No person shall be entitled to the benefits of the Agreement, if its affairs were arranged in such a manner that the main purpose or one of the main purposes was to avoid taxes to which this Agreement applies.] The following paragraph 1 of Article 7 of the MLI replaces paragraph 2 of Article 28 of this Agreement: ARTICLE 7 OF THE MLI PREVENTION OF TREATY ABUSE (Principal pu .....

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..... rectly or indirectly by one or more persons that are not residents of that Contracting State; or (b) the main purpose or one of the main purposes of any person concerned with the creation or assignment of a share, a debt-claim, or a right in respect of which the income is paid is to take advantage of these Articles by means of that creation or assignment. - - statute, statutory provisions legisl .....

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