ARTICLE 27
Limitation of Benefits
(1) A resident of a Contracting State deriving income or profits from the other Contracting State shall not be entitled in that other State to the benefits of Articles 6 to 23 if 50 percent or less of the beneficial interest in such person (or in the case of a company, 50 percent or less of the number of shares of each class of the company's shares) is owned, directly or indirectly, by any combination of one or more individual residents of a Contracting State.
(2) The provisions of paragraph (1) shall not apply if the income or profits derived in a Contracting State is derived from trading or service activities under the International Business Companies, Cap. 77 or the Societies with Restricted Liability Act, 31 SB or non-banking activities under the International Financial Services Act, Cap 325, or any other provision which may be enacted after the date of signature of this Convention and which the competent authorities of the Contracting States agree to be of a substantially similar character. A person engaged in the business of banking under the International Financial Services Act, Cap. 325 or insurance under the Exempt Insurance Act, Cap 308A or carrying on the business of an investment company under the International Business Companies Act, Cap. 77 or the Societies with Restricted Liability Act, 318B or any other provision which may be enacted after the date of signature of the Convention and which the competent authorities of the Contracting States agree to be of a substantially similar character, shall be excluded from the benefits of Articles 6 to 23.
(3) The provisions of paragraph (1) shall not apply if the person deriving the income is a company which is a resident of a Contracting State in whose principal class of shares there is a substantial and regular trading on a recognised stock exchange.
(4) If a Contracting State proposes to deny benefits to a resident of the other Contracting State by reason of this Article, the competent authorities of the Contracting States shall consult each other.