Limitation of Benefits

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..... esidents 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 such benefits. 2. A person of a Contracting State is a qualified person for a fiscal year only if such person is either: (a) Government entity; or (b) a company incorporated in either of the Contracting States, if (i .....

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..... uals 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 individuals residents of either of the Contracting States; or (d) A charitable institution or other tax exempt entity whose main .....

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..... racting States). 3. A resident of a Contracting State shall nevertheless be granted the benefits of the Agreement if the Competent Authority of the other Contracting State determines that the said resident actively carries out business in the other State and that the establishment or acquisition or maintenance of such person and the conduct of its operations did not have as one of its principal p .....

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