OECD Model Tax Convention on Income and on Capital: Condensed Version. Paris, OECD Publishing, 2014. Commentary to art. 1. § 21.3. P. 70.
1441
Ibid. § 21.4. P. 69: «The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned… to take advantage of this Article».
