TaxTMI 
TaxTMI 
Entitlement to Benefits
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.... - a Contracting State, its political subdivisions and their agencies and instrumentalities; - certain publicly-traded companies and entities; - certain affiliates of publicly-listed companies and entities; - certain non-profit organisations and recognised pension funds; - other entities that meet certain ownership and base erosion requirements; - certain collective investment vehicles. ....
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....agraphs 1 to 7. 8. a) Where (i) an enterprise of a Contracting State derives income from the other Contracting State and the first-mentioned State treats such income as attributable to a permanent establishment of the enterprise situated in a third jurisdiction, and (ii) the profits attributable to that permanent establishment are exempt from tax in the first-mentioned State, the benefits of....
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....her than the business of making, managing or simply holding investments for the enterprise's own account, unless these activities are banking, insurance or securities activities carried on by a bank, insurance enterprise or registered securities dealer, respectively). c) If benefits under this Convention are denied pursuant to the preceding provisions of this paragraph with respect to an item of ....
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....f income or capital if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant ....