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LIMITATION OF BENEFITS

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..... or not described as such. 2. 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. 3. In respect of Articles 10, 11, 12, 13 and 22, a resident of a Contracting State shall not be entitled to benefits otherwise accorde .....

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