제19921호                              관               보                2021. 1. 18.(월요일)
of the above. Such persons or authorities shall use the information only for such purposes. They
may disclose the information in public court proceedings or in judicial decisions.”
        Two new paragraphs 3 and 4 shall be inserted as follows:
“3.     If information is requested by a Contracting State in accordance with this Article, the
other Contracting State shall use its information gathering measures to obtain the requested
information, even though that other State may not need such information for its own tax
purposes. The obligation contained in the preceding sentence is subject to the limitations of
paragraph 2 but in no case shall such limitations be construed to permit a Contracting State to
decline to supply information solely because it has no domestic interest in such information.
4.      In no case shall the provisions of paragraph 2 be construed to permit a Contracting State
to decline to supply information, solely because the information is held by a bank, other financial
institution, nominee or person acting in an agency or fiduciary capacity or because the
information relates to ownership interests in a person.”
                                            ARTICLE X
        A new Article 28 (Limitation on Benefits) shall be inserted as follows:
                                             “Article 28
                                  LIMITATION ON BENEFITS
1.      Notwithstanding the provisions of any other Article of this Agreement, a resident of a
Contracting State shall not receive the benefit of any reduction in or exemption from tax provided
for in this Agreement by the other Contracting State if the main purpose or one of the main
purposes of such resident or a person connected with such resident was to obtain the benefits of
the Agreement.
2.      This Agreement shall not prevent a Contracting State from applying its domestic law on
the prevention of tax evasion or tax avoidance.
3.      The benefits under this Agreement shall not be granted to a resident of a Contracting
State who is controlled directly or indirectly by one or more persons which are not residents of
that Contracting State.”
                                           ARTICLE XI
        The ordinal numbers of Article 28 (Entry into Force) and Article 29 (Termination) of the
Agreement shall be renumbered as Article 29 (Entry into Force) and Article 30 (Termination).
                                           ARTICLE XII
1.      Each of the Contracting States shall notify to the other Contracting State the completion
of the domestic procedures required by its law for entering into force of this Protocol. This
Protocol shall enter into force on the thirtieth day following the date of the receipt of the later of
these notifications and its provisions shall thereupon have effect in both Contracting States:
        a)       in respect of taxes withheld at source, on amount paid or credited on or after the
        first day of January of the calendar year next following that in which this Protocol enters
        into force; and

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