Limitation of Benefits

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....f a Contracting State only if such a person is a qualified person as defined in paragraph 2 and meets the other conditions of this Agreement for the obtaining of any of such benefits. 2. A person of a Contracting State is a qualified person for a fiscal year only if such a person is either: a) governmental entity; or b) a company incorporated in either of the Contracting State....

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....als residents of either of the Contracting States or/and by other persons incorporated in either of the Contracting States, at least 50% of the aggregate vote or value of the shares or beneficial interest of which is owned directly or indirectly by one or more individuals residents of either of the Contracting States; or d) a charitable institution or other tax exempt entity whose main ac....

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....ting States). 3. The provisions of paragraphs 1 and 2 shall not apply and a resident of a Contracting State will be entitled to benefits of the Agreement with respect to an item of income derived from the other Contracting State, if the person actively carries on business in the State of residence (other than the business of making or managing investments for the resident's own account unle....

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.... ii) the Bombay Stock Exchange; iii) any other stock exchange recognised by the Securities and Exchange Board of India; b) in Iceland: i) the Icelandic stock exchange; ii) the stock exchanges of Amsterdam, Brussels, Copenhagen, Frankfurt, Hamburg, Helsinki, London, Oslo, Paris, Stockholm, Sydney, Tokyo, and Toronto; and c) any other stock exchan....