ARTICLE XI

"1. It is understood that a resident of a Contracting State shall not be entitled to any reduction of, or exemption from taxes provided for in this Agreement on income derived from the other Contracting State if as a result of consultations between the competent authorities of both Contracting States it is established that the main purpose or one of the main purposes of the creation or existence of such resident was to obtain the benefits under this Agreement that would not otherwise be available.

2. The provisions of paragraph 1 shall only apply to companies that are not registered in a Contracting State but claim the benefits of the Agreement."