Prevention of Treaty Abuse: treaty benefits limited by LOB and PPT rules, with active business and competent authority exceptions. Members of diplomatic missions and consular posts retain their fiscal privileges under international law or special agreements. The MLI supersedes specified treaty provisions by imposing a Simplified Limitation on Benefits test requiring residents to be 'qualified persons'-defined by individual status, state or agency status, regularly traded shares, certain non profit and pension arrangements, or ownership by qualified persons-and by providing an active conduct of business exception, ownership based gateways, competent authority discretion, and detailed definitions for stock exchange, principal class of shares, equivalent beneficiary and connected persons.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Prevention of Treaty Abuse: treaty benefits limited by LOB and PPT rules, with active business and competent authority exceptions.
Members of diplomatic missions and consular posts retain their fiscal privileges under international law or special agreements. The MLI supersedes specified treaty provisions by imposing a Simplified Limitation on Benefits test requiring residents to be "qualified persons"-defined by individual status, state or agency status, regularly traded shares, certain non profit and pension arrangements, or ownership by qualified persons-and by providing an active conduct of business exception, ownership based gateways, competent authority discretion, and detailed definitions for stock exchange, principal class of shares, equivalent beneficiary and connected persons.
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