https://www.taxtmi.com/acts?id=41727 Article 28 conditions entitlement to treaty benefits on being a qualified person-with specified categories such as individuals, the State, publicly traded entities, agreed non-profits, or entities substantially owned by qualifying residents-or on exceptions for the active conduct of a business where income from the other State is emanating from or incidental to that business (subject to enumerated exclusions and substantiality tests). The Article further provides rules for dividend-related ownership tests, definitions of key terms, a competent-authority discretionary gateway, an anti-abuse principal purpose rule, and preservation of domestic anti-avoidance rights. en-us Fri, 05 May 2023 16:46:37 +0530 Fri, 08 Nov 2024 15:06:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=41727 Article 28 conditions entitlement to treaty benefits on being a qualified person-with specified categories such as individuals, the State, publicly traded entities, agreed non-profits, or entities substantially owned by qualifying residents-or on exceptions for the active conduct of a business where income from the other State is emanating from or incidental to that business (subject to enumerated exclusions and substantiality tests). The Article further provides rules for dividend-related ownership tests, definitions of key terms, a competent-authority discretionary gateway, an anti-abuse principal purpose rule, and preservation of domestic anti-avoidance rights. Act-Rules DTAA Fri, 05 May 2023 16:46:37 +0530 https://www.taxtmi.com/acts?id=41727