Limitation of benefits denies Article 13(3B) relief for primary-purpose arrangements and shell or conduit residents.

Treaty benefits under Article 13(3B) are denied where a resident's affairs were arranged primarily to obtain those benefits or where the resident is a shell or conduit company. Shell or conduit status applies to entities with negligible or nil operations or no real and continuous business activities, subject to prescribed operational-expenditure thresholds. Listing on a recognised stock exchange or meeting the applicable expenditure threshold prevents deemed shell or conduit status.

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