Limitation of benefits: treaty benefits restricted to qualified residents, with active business and anti abuse safeguards.

Article 29 limits treaty benefits to qualified non individual residents-governmental entities; companies meeting listing or ownership tests; partnerships or similar entities meeting ownership tests; and qualifying tax exempt institutions-and bars benefits where a majority of gross income is paid to non residents in deductible forms, with exceptions for arm's length commercial payments and specified bank obligations. An active business exception permits benefits for residents carrying on substantive business in their residence State when income is connected with that business. Competent Authorities may recognize stock exchanges and deny or grant benefits where principal purposes concern tax avoidance.

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