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of <h1>Understanding Entitlement to Benefits Under OECD and UN Model Tax Conventions: Qualified Persons and Exceptions Explained</h1> The the criteria for entitlement to benefits under international tax conventions, specifically the OECD and UN Model Tax Conventions. It describes the conditions under which residents of a contracting state qualify for treaty benefits, emphasizing the concept of a 'qualified person.' Qualified persons include individuals, certain publicly-traded companies, non-profit organizations, and recognized pension funds. The text also discusses scenarios where non-qualified persons might still receive benefits, such as engaging in active business or being a headquarters company. Additionally, it addresses discretionary relief, derivative benefits, and the denial of benefits if the principal purpose of a transaction is to obtain such benefits. Definitions and conditions for terms like 'qualified person,' 'connected persons,' and 'equivalent beneficiary' are detailed to ensure clarity in application.
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