https://www.taxtmi.com/acts?id=32332 Limitation of Benefits denies benefits where a resident's affairs are arranged with the primary purpose of obtaining treaty advantages. A shell/conduit company-defined by negligible or no real and continuous business activities-is ineligible. A resident is deemed a shell/conduit company if its operational expenditure in the relevant contracting State in the twelve months preceding the gain falls below a specified threshold, and is deemed not to be one if listed on a recognized stock exchange or if expenditure meets or exceeds that threshold. en-us Wed, 16 May 2018 10:11:42 +0530 Thu, 28 Nov 2024 12:11:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=32332 Limitation of Benefits denies benefits where a resident's affairs are arranged with the primary purpose of obtaining treaty advantages. A shell/conduit company-defined by negligible or no real and continuous business activities-is ineligible. A resident is deemed a shell/conduit company if its operational expenditure in the relevant contracting State in the twelve months preceding the gain falls below a specified threshold, and is deemed not to be one if listed on a recognized stock exchange or if expenditure meets or exceeds that threshold. Act-Rules DTAA Wed, 16 May 2018 10:11:42 +0530 https://www.taxtmi.com/acts?id=32332