Limitation of benefits restricts treaty benefits to entities with qualifying ownership, substantive business ties, or recognized listings.

Article 28 conditions treaty benefits for non individual residents on qualification by ownership, listing or activity: governmental entities; companies listed on a recognised stock exchange; companies or partnerships at least half owned by resident individuals or qualifying domestic persons; and charitable or tax exempt entities carrying on main activities in either Contracting State. Benefits are denied if over half of gross income is paid to non residents in deductible forms, subject to specified carve outs. An active business exception applies where income is connected with business carried on in the State of residence. The Competent Authority may permit benefits where obtaining treaty benefits was not a principal purpose, and an anti abuse rule bars arrangements aimed at tax avoidance.

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