Limitation of benefits: treaty benefits denied where ownership or income is predominantly controlled by non residents, subject to active business exception. Article 27 denies treaty benefits to non-individual residents whose creation, ownership or conduct has as a main purpose obtaining DTAA benefits otherwise unavailable; it identifies indicative circumstances such as corporate and partnership ownership concentrated in non-residents, charitable entities operating outside the Contracting States, and situations where most gross income is paid to non-residents as deductible payments. Benefits remain available if the resident actively carries on business in its State of residence and the income is connected with or incidental to that business, or if the competent authority determines there was no principal purpose of obtaining treaty benefits.