Treaty benefit entitlement limits access to DTAA relief through qualified person tests, active business rules, and principal purpose safeguards.

Entitlement to benefits under the Convention is restricted to a resident of a Contracting State that is a qualified person at the time the benefit would otherwise be available, subject to specific exceptions. A non-qualified resident may still obtain benefits for income derived from the other Contracting State if engaged in the active conduct of a business, if equivalent beneficiaries own at least 75 per cent of the resident, or through competent-authority relief where treaty benefit was not one of the principal purposes of the arrangement or operations. The Article also defines recognised stock exchange, connected persons, equivalent beneficiary, and contains a denial rule for certain low-taxed third-jurisdiction permanent establishment income, subject to exceptions and relief.

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