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of <h1>Understanding Article 28 of Armenia's DTAA: Limitation of Benefits for Qualified Persons and Exceptions Explained.</h1> Article 28 of the Double Tax Avoidance Agreement (DTAA) between Armenia and another contracting state outlines the limitation of benefits provisions. A resident of a contracting state can access treaty benefits only if they are a 'qualified person,' defined as an individual, a qualified governmental entity, a publicly traded company, a tax-exempt entity, or other entities meeting specific ownership and income criteria. Exceptions allow benefits for residents actively conducting substantial business. The article also restricts benefits for companies with disproportionate income distribution to non-qualified persons. Benefits may still be granted if the competent authority determines the primary purpose was not to obtain treaty benefits.
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