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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>DTAA Article 24: Limitation of Benefits for Non-Individuals; Treaty Benefits Tied to 'Qualified Person' Status</h1> Article 24 of the Double Tax Avoidance Agreement (DTAA) between Iceland and another Contracting State outlines the limitation of benefits. It specifies that a non-individual resident deriving income from the other state is entitled to treaty benefits only if deemed a 'qualified person.' This includes government entities, publicly traded companies, partnerships, or tax-exempt entities, provided they meet ownership and income criteria. Benefits are denied if over 50% of income is paid to non-residents. Exceptions exist for active business operations or if a competent authority determines no tax avoidance intent. Recognized stock exchanges are defined for qualification purposes.
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