TMI BlogLIMITATION OF BENEFITSX X X X Extracts X X X X X X X X Extracts X X X X ..... Contracting 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tnership or association of persons, at least 50% or more of whose beneficial interests is owned by one or more individuals residents of either of the Contracting States 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 resident ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in connection with a transaction entered into with the permanent establishment of the bank situated in either of the Contracting States). 3. The provisions of paragraphs 1 and 2 shall not 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s Article the term 'recognised stock exchange' means ( a ) in India, any stock exchange which is recognised under the Securities Contracts (Regulation) Act, 1956; and ( b ) any other stock exchange which the competent authorities agree to recognise for the purposes of this Article. 6. Notwithstanding anything contained in paragraphs 2 to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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