OECD Model Tax Convention on Income and on Capital: Condensed Version. Paris, OECD Publishing, 2014. Commentary to art. 1. § 19a-19e. P. 66–67.

Ibid. § 19a. General bona fide provision: «The foregoing provisions shall not apply where the company establishes that the principal purpose of the company, the conduct of its business and the acquisition or maintenance by it of the shareholding or other property from which the income in question is derived, are motivated by sound business reasons and do not have as primary purpose the obtaining of any benefits under this Convention».