Limitation of Benefit

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..... o the abuses of law (including tax treaties) may be applied to the treatment of such abuses. 2. It is understood that the benefits under this Convention shall not be granted to a person, which is not .....

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..... in purposes of the creation, existence, incorporation, registration or presence of such a resident or of the transaction undertaken by him, was to obtain benefits under this Convention that would not .....

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