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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 29 Albania DTAA narrows treaty benefits to qualified residents, denying advantages for income routing and tax-avoidance arrangements</h1> Article 29 limits treaty benefits under the Albania DTAA to 'qualified persons,' primarily residents that are governmental entities, listed companies, locally owned companies, qualifying partnerships or associations, and charitable or tax-exempt entities, subject to ownership and gross income tests. Benefits are denied if over 50% of a person's gross income is paid, in deductible form, to non-residents, except for arm's length business and certain banking payments. Non-qualified residents may still obtain benefits if they actively conduct business in their residence state and the relevant income is connected with that business, or if the competent authority finds that obtaining treaty benefits was not a principal purpose. No person is entitled to benefits where arrangements mainly seek to avoid covered taxes.
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