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of <h1>Article 27 in DTAA Limits Benefits for Entities with Over 50% Non-Resident Ownership or Charitable Institutions Not Active Locally.</h1> Article 27 of the Double Tax Avoidance Agreement (DTAA) between Romania and another Contracting State outlines the limitation of benefits for entities seeking treaty advantages. A resident entity of a Contracting State is denied treaty benefits if its primary purpose is to obtain benefits not otherwise available. This applies if over 50% of the entity's shares or interests are owned by non-residents, or if it is a charitable institution not primarily active in either state. Exceptions exist if the entity conducts active business in its residence state or if the competent authority confirms that obtaining treaty benefits was not a principal purpose.
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