Limitation of Benefits rule: treaty benefits limited to qualified persons, with active business and anti abuse safeguards. The Limitation of Benefits clause confines treaty benefits to residents who are qualified persons-including individuals, certain governmental entities, listed companies, charities, and other persons meeting ownership and deductible payment concentration criteria-or who satisfy an active business exception. It provides attribution rules for connected persons and partnerships, a substantiality test for cross border business activity, an anti abuse rule excluding disproportionate income allocated to a share class largely owned by non qualified persons, and a competent authority gateway where treaty benefits are not principally sought.