Principal purpose test: treaty benefits denied when obtaining the benefit was a main purpose, unless aligned with treaty object. A treaty benefit shall not be granted if it is reasonable to conclude, from all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction resulting in the benefit, unless it is established that granting the benefit would be in accordance with the object and purpose of the relevant treaty provisions.
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Provisions expressly mentioned in the judgment/order text.
Principal purpose test: treaty benefits denied when obtaining the benefit was a main purpose, unless aligned with treaty object.
A treaty benefit shall not be granted if it is reasonable to conclude, from all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction resulting in the benefit, unless it is established that granting the benefit would be in accordance with the object and purpose of the relevant treaty provisions.
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