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of <h1>Article 28: Chile DTAA Limits Benefits to Qualified Residents, Defines Criteria for Individuals and Entities, Addresses Tax Avoidance</h1> Article 28 of the Chile Double Tax Avoidance Agreement (DTAA) outlines the Limitation of Benefits, specifying that residents of a Contracting State are entitled to benefits only if they qualify under certain criteria. A 'qualified person' includes individuals, government entities, publicly traded companies, non-profit organizations, and entities owned by qualifying residents. Benefits may also be granted if the resident is actively conducting business, with specific exclusions. Additional provisions address ownership structures, income thresholds, and tax avoidance. Competent authorities may grant benefits on a discretionary basis, and the agreement allows for the application of domestic tax laws to prevent tax avoidance or evasion.
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