TaxTMI 
TaxTMI 
Entitlement to benefits
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....ion or local authority thereof, or an agency or instrumentality of that State, political subdivision or local authority; c) a company or other entity, if the principal class of its shares is regularly traded on one or more recognised stock exchanges; d) a person, other than an individual, that is a non-profit organisation agreed upon by the competent authorities of the Contracting States, e) a person other than an individual if, at that time and on at least half of the days of a twelvemonth period that includes that time, persons who are residents of that Contracting State and that are entitled to benefits of this Convention under subparagraphs a) to d) own, directly or indirectly, at least 50 per cent of the shar....
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.... State to which the item is related is substantial in relation to the same or complementary business activity carried on by the resident or such connected person in the other Contracting State. Whether a business activity is substantial for the purposes of this paragraph shall be determined based on all the facts and circumstances. c) For purposes of applying this paragraph, activities conducted by connected persons with respect to a resident of a Contracting State shall be deemed to be conducted by such resident. 4. A resident of a Contracting State that is not a qualified person shall nevertheless be entitled to a benefit that would otherwise be accorded by this Convention with respect to an item of income if, at the time when....
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.... (ii) any other stock exchange agreed upon by the competent authorities of the Contracting States; b) with respect to entities that are not companies, the term "shares" means interests that are comparable to shares; c) the term "principal class of shares" means the class or classes of shares of a company or entity which represents the majority of the aggregate vote and value of the company or entity; d) two persons shall be "connected persons" if one owns, directly or indirectly, at least 50 per cent of the beneficial interest in the other (or, in the case of a company, at least 50 per cent of the aggregate vote and value of the company's shares) or another person owns, directly or indirectly, at least 50 per....
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....utable to that permanent establishment are exempt from tax in the first-mentioned State, the benefits of this Convention shall not apply to any item of income on which the tax in the third jurisdiction is less than the lower of 15 per cent of the amount of that item of income and 60 per cent of the tax that would be imposed in the first-mentioned State on that item of income if that permanent establishment were situated in the first-mentioned State. In such a case any income to which the provisions of this paragraph apply shall remain taxable according to the domestic law of the other State, notwithstanding any other provisions of the Convention. b) The preceding provisions of this paragraph shall not apply if the income d....