https://www.taxtmi.com/acts?id=51368 Article 22 conditions entitlement to treaty benefits on being a qualified person or satisfying specified alternative tests: categories of individuals and entities, publicly traded company or primary place of management tests, five or fewer owners and base erosion limits, pension and ownership thresholds, and ownership/base erosion tests for other entities. It provides an active conduct of trade or business exception, company specific ownership and headquarters rules, detailed definitional tests (including qualifying intermediate owner, tested group and gross income), and a residual competent authority discretionary gateway based on substantial nontax nexus. en-us Wed, 21 May 2025 16:16:25 +0530 Wed, 21 May 2025 16:16:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51368 Article 22 conditions entitlement to treaty benefits on being a qualified person or satisfying specified alternative tests: categories of individuals and entities, publicly traded company or primary place of management tests, five or fewer owners and base erosion limits, pension and ownership thresholds, and ownership/base erosion tests for other entities. It provides an active conduct of trade or business exception, company specific ownership and headquarters rules, detailed definitional tests (including qualifying intermediate owner, tested group and gross income), and a residual competent authority discretionary gateway based on substantial nontax nexus. Act-Rules DTAA Wed, 21 May 2025 16:16:25 +0530 https://www.taxtmi.com/acts?id=51368