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<h1>DTAA Article 28: Benefits Limited for Non-Individual Residents; Criteria Include Public Trading or Charitable Status; Anti-Avoidance Measures Applied.</h1> Article 28 of the Double Tax Avoidance Agreement (DTAA) between Tajikistan and another Contracting State outlines the limitation of benefits. It specifies that a non-individual resident of a Contracting State can only receive benefits if they qualify under certain criteria, such as being a governmental entity, a publicly traded company, or a charitable institution. However, benefits are denied if more than 50% of the entity's income is paid to non-residents, except for certain business-related payments. Additionally, benefits may be granted if the entity's operations are not primarily for obtaining treaty benefits. Recognized stock exchanges are defined, and entities arranged primarily to avoid taxes are excluded from benefits.