Entitlement to benefits: treaty access limited to qualified persons, subject to active business and principal purpose anti abuse conditions. Article 29 conditions treaty benefits on being a qualified person defined by categorical tests (individuals; governments; listed or primarily managed companies; companies majority owned by a few qualifying traded entities; recognised non profits and pension funds; collective investment vehicles where applicable; and persons meeting residence based ownership and deductible payment limits). It provides an active conduct of business exception, a headquarters company rule for multinational groups, a discretionary competent authority relief for non qualified residents, detailed definitions for application, and two anti abuse measures: a low tax third jurisdiction PE rule and a principal purpose test.