Direct Tax Avoidance Agreements

Taipei

Article 28

LIMITATION OF BENEFITS

1. Notwithstanding the provisions of any other Article of this Agreement, a resident of a territory shall not be entitled to the benefits of this Agreement if the primary purpose or one of the primary purposes of such resident or a person connected with such resident was to obtain the benefits of this Agreement.

2. The cases of legal entities not having bona fide business activities shall be; covered by the provisions of this Article.