9911796707
TMI BlogLimitation of BenefitsX X X X Extracts X X X X X X X X Extracts X X X X ..... cting State only if such a person is a qualified person 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 fiscal year only if such a person is either: (a) a governmental entity; or (b) a company incorporated in either of the Contracting States, if - (i) the principal c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ates or/and by other persons incorporated in either of the Contracting States, at least 50% 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 activities are carried on in either of the Contracting ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t 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 resident actively carries on business in the State of residence (other than the business of making or managing investments for the resident's own account unless these activities are banking, insurance or security activities) and the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hange which the competent authorities agree to recognise for the purposes of this Article. 6. Notwithstanding anything contained in paragraphs 2 to 5 above, any person shall not be entitled to the benefits of this Agreement, if its affairs were arranged in such a manner as if it was the main purpose or one of the main purposes to avoid taxes to which this Agreement applies. - - statute, statutor ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
