Treaty benefit limitation restricts relief through qualification, ownership, active-business and principal-purpose anti-abuse tests for cross-border income.

Treaty benefits for non-individual residents are generally restricted to qualified persons meeting specified listing, ownership, institutional or tax-exempt status conditions. Benefits may be denied where gross income is substantially routed through deductible payments to non-residents, subject to stated exclusions. Relief remains available for income connected with an active business in the residence State and may be granted following a competent-authority determination on principal purpose. A separate principal-purpose anti-abuse rule denies benefits arising from arrangements or transactions principally intended to obtain them unless consistent with the relevant treaty provisions' object and purpose.

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