Limitation of benefits restricts treaty relief to qualified residents, active businesses, or where not principally obtained to avoid abuse.

Article 28 conditions entitlement to treaty benefits on being a qualified person-with specified categories such as individuals, the State, publicly traded entities, agreed non-profits, or entities substantially owned by qualifying residents-or on exceptions for the active conduct of a business where income from the other State is emanating from or incidental to that business (subject to enumerated exclusions and substantiality tests). The Article further provides rules for dividend-related ownership tests, definitions of key terms, a competent-authority discretionary gateway, an anti-abuse principal purpose rule, and preservation of domestic anti-avoidance rights.

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