https://www.taxtmi.com/acts?id=8358 Article 24 conditions treaty benefits on a person (other than an individual) being a qualified person: governmental entities; listed companies on recognised stock exchanges; companies, partnerships or associations meeting a fifty percent ownership test by residents or qualifying domestic persons; or charitable/tax exempt entities with primary activities in either Contracting State. It disqualifies entities whose majority gross income is paid to non residents as deductible payments (with certain business and bank payment exceptions), provides an active business exception, authorises competent authority determinations on principled purpose, and includes an overarching anti abuse prohibition. en-us Sun, 10 Feb 2008 21:55:32 +0530 Fri, 15 Nov 2024 16:54:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=8358 Article 24 conditions treaty benefits on a person (other than an individual) being a qualified person: governmental entities; listed companies on recognised stock exchanges; companies, partnerships or associations meeting a fifty percent ownership test by residents or qualifying domestic persons; or charitable/tax exempt entities with primary activities in either Contracting State. It disqualifies entities whose majority gross income is paid to non residents as deductible payments (with certain business and bank payment exceptions), provides an active business exception, authorises competent authority determinations on principled purpose, and includes an overarching anti abuse prohibition. Act-Rules DTAA Sun, 10 Feb 2008 21:55:32 +0530 https://www.taxtmi.com/acts?id=8358