https://www.taxtmi.com/acts?id=37659 restricts treaty benefits for non individual residents unless they are a qualified person-including governmental entities, listed companies on a recognized stock exchange, resident owned companies or partnerships meeting prescribed ownership thresholds, and qualifying charitable or tax exempt entities-subject to an anti leakage rule disqualifying entities paying over half their gross income to non residents in deductible form (with specified exceptions). Treaty benefits may nonetheless be available under an active business exception for income connected to substantive resident business activities or where the Competent Authority finds no principal purpose of obtaining treaty benefits. en-us Thu, 19 Sep 2019 12:36:39 +0530 Wed, 27 Nov 2024 12:14:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37659 restricts treaty benefits for non individual residents unless they are a qualified person-including governmental entities, listed companies on a recognized stock exchange, resident owned companies or partnerships meeting prescribed ownership thresholds, and qualifying charitable or tax exempt entities-subject to an anti leakage rule disqualifying entities paying over half their gross income to non residents in deductible form (with specified exceptions). Treaty benefits may nonetheless be available under an active business exception for income connected to substantive resident business activities or where the Competent Authority finds no principal purpose of obtaining treaty benefits. Act-Rules DTAA Thu, 19 Sep 2019 12:36:39 +0530 https://www.taxtmi.com/acts?id=37659