Principal purpose limitation on tax treaty benefits prevents treaty advantages obtained as a principal purpose, subject to an object and purpose exception. A rule limits entitlement to tax treaty benefits where it is reasonable to conclude that obtaining the benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit would be consistent with the object and purpose of the relevant treaty provisions.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Principal purpose limitation on tax treaty benefits prevents treaty advantages obtained as a principal purpose, subject to an object and purpose exception.
A rule limits entitlement to tax treaty benefits where it is reasonable to conclude that obtaining the benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit would be consistent with the object and purpose of the relevant treaty provisions.
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