Treaty benefits restriction bars residents using shell or conduit structures from claiming preferential capital gains relief.

A resident is barred from claiming paragraph 4A or 4C benefits where the arrangement's primary purpose is to obtain those benefits; a shell or conduit company-an entity with negligible operations or no real and continuous activities-is similarly denied benefits. Entities are deemed shell or conduit if annual operational expenditure in the Contracting State falls below prescribed national thresholds for the applicable look back periods, while listing on a recognised stock exchange or meeting the expenditure thresholds exempts an entity from being treated as a shell or conduit.

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