Lodewijk P.W. Berger, Vincent van der Lans. The Improper Use of Holding Companies. Selected Recent Developments. 2011. P. 7. Footnotes 22, 23.

Article 29: «[a]person that is a resident of a Contracting State and derives income from the other Contracting State shall not be entitled to relief from taxation in that other State otherwise provided for in this Convention if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of such item of income to take advantage of the provisions of this Convention».