- 1
- This Convention shall apply to persons who are residents of one or both of the Contracting States.
- 2
- A benefit under this Convention shall not be granted in respect of an item of income or capital if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Convention. The competent authority of a Contracting State shall notify the competent authority of the other Contracting State before denying a benefit under this paragraph.
