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LIMITATION OF BENEFITS

Article 28 - DTAA - Article 28 - ARTICLE 28 1. Nothing in this Agreement shall affect the application of the domestic provisions to prevent tax evasion or tax avoidance. 2. Benefits of this Agreement shall not be available to a resident of a Contracting State, or with respect to any transaction undertaken by such a resident, if the main purpose or one of the main purposes of the creation or existence of such a resident or of the transaction undertaken by him, was to obtain benefits under this Ag .....

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