S.L. 123.8 Art. 7main purpose or or assignment of to take advantage relief from of the first State shall notify

The provisions of this Article shall not apply if it was the one of the main purposes of any person concerned with the creation the shares or other rights in respect of which the dividend is paid of this Article by means of that creation or assignment.

In the event that a resident of a Contracting State is denied taxation in the other Contracting State by reason of the provisions sentence of this paragraph, the competent authority of that other the competent authority of the first-mentioned State. Article 11 Interest