Limitation on treaty benefits restricts shell entities and conditions capital gains and information exchange under the amended tax protocol. The Protocol amends treaty allocation of taxing rights by providing that gains from alienation of property not otherwise covered are taxable only in the alienator's State of residence, enhances exchange of information obligations through Competent Authorities, establishes an intergovernmental review group, and introduces a Limitation on Treaty Benefits denying benefits where arrangements are primarily to obtain treaty advantages and excluding shell/conduit companies unless objective tests (listing or expenditure) are met; it also caps source state tax on royalties where the recipient is beneficial owner.