Income not expressly mentioned in the aforementioned Articles of this Convention may be taxed in accordance with the tax laws of the Contracting States concerned. However, in order to avoid the misuse of this derogation, in particular by third-country nationals who set up holding companies in Singapore to benefit from the capital gains exemption, the contract added a `limitation of benefits (LOB)` clause. Under this clause, a company registered in Singapore is not entitled to the capital gains exemption if the sole purpose of setting up the company was to benefit from that benefit. In addition, companies that have a negligible business in Singapore, without business continuity, are not entitled to this benefit. Under the LOB clause, the agreement does not apply to shell companies. If Singapore and India did not have a DBA in place, the company`s profits could be taxed in Singapore and India. . . .