Limitation on benefits: treaty relief limited to qualifying resident ownership or publicly traded companies, with active trade exception. Article 24 limits treaty relief to non individual residents that satisfy ownership and income use conditions: more than 50% beneficial interest or more ... Summary
Limitation on benefits: treaty relief limited to qualifying resident ownership or publicly traded companies, with active trade exception.
Article 24 limits treaty relief to non individual residents that satisfy ownership and income use conditions: more than 50% beneficial interest or more than 50% of each class of shares must be held by qualifying residents or citizens, and the income must not be substantially used to meet liabilities to non qualifying persons. Exceptions apply where income is connected with the active conduct of a trade or business (excluding passive investment except specified banking or insurance activities) and where the company's principal class of shares is regularly traded on a recognized stock exchange. Competent authority may nonetheless grant benefits.
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