Entitlement to benefits: access limited to qualified persons with anti abuse and competent authority relief mechanisms. Entitlement to treaty benefits is limited to residents who are qualified persons, defined to include individuals, governments, publicly traded companies and affiliates, certain non profits and pension funds, collective investment vehicles, and other entities meeting ownership and base erosion tests. Exceptions allow benefits for non qualified residents engaged in the active conduct of business, for entities with qualifying ownership by benefit entitled persons, and for headquarters companies; competent authorities may grant relief in specific cases. Anti abuse provisions deny benefits where income is attributed to a permanent establishment in a third jurisdiction with low taxation, subject to an active business exception and discretionary competent authority relief, and a principal purpose limitation bars benefits obtained principally to secure treaty advantages.