https://www.taxtmi.com/acts?id=53775 under the Convention is restricted to a resident of a Contracting State that is a qualified person at the time the benefit would otherwise be available, subject to specific exceptions. A non-qualified resident may still obtain benefits for income derived from the other Contracting State if engaged in the active conduct of a business, if equivalent beneficiaries own at least 75 per cent of the resident, or through competent-authority relief where treaty benefit was not one of the principal purposes of the arrangement or operations. The Article also defines recognised stock exchange, connected persons, equivalent beneficiary, and contains a denial rule for certain low-taxed third-jurisdiction permanent establishment income, subject to exceptions and relief. en-us Tue, 31 Mar 2026 14:59:39 +0530 Tue, 31 Mar 2026 14:59:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=53775 under the Convention is restricted to a resident of a Contracting State that is a qualified person at the time the benefit would otherwise be available, subject to specific exceptions. A non-qualified resident may still obtain benefits for income derived from the other Contracting State if engaged in the active conduct of a business, if equivalent beneficiaries own at least 75 per cent of the resident, or through competent-authority relief where treaty benefit was not one of the principal purposes of the arrangement or operations. The Article also defines recognised stock exchange, connected persons, equivalent beneficiary, and contains a denial rule for certain low-taxed third-jurisdiction permanent establishment income, subject to exceptions and relief. Act-Rules DTAA Tue, 31 Mar 2026 14:59:39 +0530 https://www.taxtmi.com/acts?id=53775