Entitlement to Benefits

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....ers - an individual; - 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 ....

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....e be denied under paragraph 1. 7. Definitions applicable for the purposes of paragraphs 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....

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....r is incidental to, the active conduct of a business carried on through the permanent establishment (other 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....

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....provisions of this Convention, a benefit under this Convention shall not be granted in respect of an item of 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 grant....