https://www.taxtmi.com/acts?id=51430 Article 29 conditions treaty benefits on being a qualified person defined by categorical tests (individuals; governments; listed or primarily managed companies; companies majority owned by a few qualifying traded entities; recognised non profits and pension funds; collective investment vehicles where applicable; and persons meeting residence based ownership and deductible payment limits). It provides an active conduct of business exception, a headquarters company rule for multinational groups, a discretionary competent authority relief for non qualified residents, detailed definitions for application, and two anti abuse measures: a low tax third jurisdiction PE rule and a principal purpose test. en-us Thu, 22 May 2025 12:48:17 +0530 Tue, 27 May 2025 12:14:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51430 Article 29 conditions treaty benefits on being a qualified person defined by categorical tests (individuals; governments; listed or primarily managed companies; companies majority owned by a few qualifying traded entities; recognised non profits and pension funds; collective investment vehicles where applicable; and persons meeting residence based ownership and deductible payment limits). It provides an active conduct of business exception, a headquarters company rule for multinational groups, a discretionary competent authority relief for non qualified residents, detailed definitions for application, and two anti abuse measures: a low tax third jurisdiction PE rule and a principal purpose test. Act-Rules DTAA Thu, 22 May 2025 12:48:17 +0530 https://www.taxtmi.com/acts?id=51430