Limitation of benefits

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.... of a Contracting State only if such a person has the qualifications 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 year of income only if such a person is either: (a) Governmental entity; or (b) A company incorporated in either of the Contracti....

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....terests is owned by one or more individual residents of either of the Contracting States or/and by other persons incorporated in either of the Contracting States, at least 50 per cent of the aggregate vote or value of the shares or beneficial interest of which is owned directly or indirectly by one or more individual residents of either of the Contracting States, or (d) A charitable insti....

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....ent of the bank situated in either of the Contracting States). 3. The provisions of Paragraph 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 State, if the person actively carries on business in the State of residence (other than the business of making or managing investments for....

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....dia, a stock exchange which is for the time being recognised by the Central Government under Section 4 of the Securities Contracts (Regulation) Act, 1956; (b) in Tanzania, the "Dar es Salaam Stock Exchange" or any other exchange recognised by the Capital Markets and Securities Authority under the Capital Markets and Securities Authority Act, Cap. 79; and (c) any other stock excha....