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of <h1>Comprehensive Framework for Treaty Benefits Clarifies Eligibility, Ownership Criteria, and Anti-Avoidance Safeguards</h1> The statutory provision addresses entitlement to treaty benefits under a Double Tax Avoidance Agreement (DTAA). It defines qualified persons eligible for benefits, including individuals, government entities, publicly-traded companies, and certain organizations. The provision allows treaty benefits for entities engaged in active business, provides mechanisms for ownership-based qualification, and includes anti-abuse provisions to prevent tax avoidance. Competent authorities retain discretion to grant benefits in specific circumstances, with a principal purpose test to prevent improper treaty shopping.
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