https://www.taxtmi.com/acts?id=4180 The Limitation of Benefits clause confines treaty benefits to residents who are qualified persons-including individuals, certain governmental entities, listed companies, charities, and other persons meeting ownership and deductible payment concentration criteria-or who satisfy an active business exception. It provides attribution rules for connected persons and partnerships, a substantiality test for cross border business activity, an anti abuse rule excluding disproportionate income allocated to a share class largely owned by non qualified persons, and a competent authority gateway where treaty benefits are not principally sought. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 25 Oct 2024 14:14:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4180 The Limitation of Benefits clause confines treaty benefits to residents who are qualified persons-including individuals, certain governmental entities, listed companies, charities, and other persons meeting ownership and deductible payment concentration criteria-or who satisfy an active business exception. It provides attribution rules for connected persons and partnerships, a substantiality test for cross border business activity, an anti abuse rule excluding disproportionate income allocated to a share class largely owned by non qualified persons, and a competent authority gateway where treaty benefits are not principally sought. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4180