https://www.taxtmi.com/acts?id=15108 Article 28 conditions DTAA benefits on status as a qualified person-including governmental entities, listed companies, resident owned companies, resident majority partnerships, and resident charitable or tax exempt entities-and disqualifies entities paying most gross income to non residents via deductible payments, subject to ordinary course and banking carve outs. Benefits also arise if the resident actively carries on business in the State of residence and income is connected to that business. The Competent Authority may permit benefits absent principal purpose of treaty shopping; recognised stock exchanges are defined and mutual recognition is permitted. An overarching anti abuse rule denies benefits for arrangements whose main purpose is tax avoidance. en-us Tue, 30 Aug 2011 14:41:15 +0530 Sat, 30 Nov 2024 12:35:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15108 Article 28 conditions DTAA benefits on status as a qualified person-including governmental entities, listed companies, resident owned companies, resident majority partnerships, and resident charitable or tax exempt entities-and disqualifies entities paying most gross income to non residents via deductible payments, subject to ordinary course and banking carve outs. Benefits also arise if the resident actively carries on business in the State of residence and income is connected to that business. The Competent Authority may permit benefits absent principal purpose of treaty shopping; recognised stock exchanges are defined and mutual recognition is permitted. An overarching anti abuse rule denies benefits for arrangements whose main purpose is tax avoidance. Act-Rules DTAA Tue, 30 Aug 2011 14:41:15 +0530 https://www.taxtmi.com/acts?id=15108