TMI BlogLIMITATION OF BENEFITSX X X X Extracts X X X X X X X X Extracts X X X X ..... 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 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) Governmental entity; or (b) a company incorporated in either of the Contracting States, if ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 individual residents of either of the Contracting States, or (d) A charitable institution or any other tax-exempt entity whose main activities are carrie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rovisions of Paragraph 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 person 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, insu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t under Section 4 of the' Securities Contracts (Regulation) Act, 1956. (b) in Sri Lanka any stock exchange licensed by the Security and Exchange Commission of Sri Lanka. (c) any other stock exchange which the Competent Authorities agree to recognize for the purposes of this Article. 6. Notwithstanding anything contained in the preceding paragraphs of this Article, any person (inclu ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
