"Article 26.2
Limitation of Benefits
Notwithstanding the provisions of any other Article of this Convention, a resident of a Contracting State shall not receive the benefit of any reduction in or exemption from tax provided for in the Convention by the other Contracting State if the main purpose or one of the main purposes of such resident or a person connected with such resident was to obtain the benefits of the Convention."
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Protocol Amending the Convention Between the Government of the Russian Federation and the Government of the Republic of Austria... |