Article 85
As regards direct taxation, nothing in this Agreement shall have the effect of:
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extending the fiscal advantages granted by either Party in any international agreement or arrangement by which it is bound,
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preventing the adoption or application by either Party of any measure aimed at preventing the avoidance or evasion of taxes,
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opposing the right of either Party to apply the relevant provisions of its tax legislation to taxpayers who are not in identical situation, in particular as regards their place of residence.