Anti-abuse rule for permanent establishments restricts treaty benefits where third jurisdiction tax is substantially lower, with limited exceptions. Diplomatic and consular personnel retain fiscal immunities under international law and special agreements. The Convention applies an Anti abuse Rule for Permanent Establishments: treaty benefits are denied where income is attributed to a permanent establishment in a third jurisdiction and tax there is substantially lower than if the establishment were in the resident's State, with an exception for income connected to the active conduct of a business and with potential competent authority relief. The Convention also applies the Principal Purpose Test, denying benefits where obtaining them was one of the principal purposes of an arrangement unless consistent with the treaty's object and purpose.