Статья 6(m) протокола от марта 1988 г. к данному налоговому соглашению: «Nothing in this Convention shall affect the application of the domestic provisions to prevent fiscal evasion and tax avoidance concerning the limitation of expenses and any deductions arising from transactions between enterprises of a Contracting State and associated enterprises or permanent establishments of such enterprises which are situated in the other Contracting State, if the main purpose of the transactions undertaken between them was to obtain benefits under this Convention that would not otherwise be available».
