https://www.taxtmi.com/acts?id=37659 Treaty benefits for non-individual residents are generally restricted to qualified persons meeting specified listing, ownership, institutional or tax-exempt status conditions. Benefits may be denied where gross income is substantially routed through deductible payments to non-residents, subject to stated exclusions. Relief remains available for income connected with an active business in the residence State and may be granted following a competent-authority determination on principal purpose. A separate principal-purpose anti-abuse rule denies benefits arising from arrangements or transactions principally intended to obtain them unless consistent with the relevant treaty provisions' object and purpose. en-us Thu, 19 Sep 2019 12:36:39 +0530 Sat, 18 Jul 2026 11:09:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37659 Treaty benefits for non-individual residents are generally restricted to qualified persons meeting specified listing, ownership, institutional or tax-exempt status conditions. Benefits may be denied where gross income is substantially routed through deductible payments to non-residents, subject to stated exclusions. Relief remains available for income connected with an active business in the residence State and may be granted following a competent-authority determination on principal purpose. A separate principal-purpose anti-abuse rule denies benefits arising from arrangements or transactions principally intended to obtain them unless consistent with the relevant treaty provisions' object and purpose. Act-Rules DTAA Thu, 19 Sep 2019 12:36:39 +0530 https://www.taxtmi.com/acts?id=37659