Limitation of benefits restricts treaty benefits unless an entity satisfies qualifying ownership, active business, or anti abuse tests. Limitation of benefits restricts treaty benefits for non individual residents unless they are a qualified person-including governmental entities, listed companies on a recognized stock exchange, resident owned companies or partnerships meeting prescribed ownership thresholds, and qualifying charitable or tax exempt entities-subject to an anti leakage rule disqualifying entities paying over half their gross income to non residents in deductible form (with specified exceptions). Treaty benefits may nonetheless be available under an active business exception for income connected to substantive resident business activities or where the Competent Authority finds no principal purpose of obtaining treaty benefits.