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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 28 of DTAA Limits Treaty Benefits for Non-Individuals; Conditions Include Local Ownership and Active Business Operations.</h1> Article 28 of the Double Tax Avoidance Agreement (DTAA) between two contracting states outlines the limitation of benefits. It specifies that a non-individual resident of a contracting state can access treaty benefits only if they qualify under certain conditions, such as being a governmental entity, a publicly traded company, or a partnership with significant local ownership. Benefits are denied if the entity's income is primarily paid to non-residents or if tax avoidance is a primary purpose. Exceptions exist for businesses actively operating in their state of residence. Recognized stock exchanges are defined for eligibility purposes.
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