Principal Purposes Test bars treaty benefits where obtaining them was a principal purpose, unless consistent with treaty object and purpose. Diplomatic and consular fiscal privileges remain unaffected by the Convention and are preserved under international law and special agreements. The Multilateral Instrument's Principal Purposes Test supersedes the Convention's provisions for treaty abuse: a benefit shall not be granted if it is reasonable to conclude that obtaining the benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit aligns 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 Purposes Test bars treaty benefits where obtaining them was a principal purpose, unless consistent with treaty object and purpose.
Diplomatic and consular fiscal privileges remain unaffected by the Convention and are preserved under international law and special agreements. The Multilateral Instrument's Principal Purposes Test supersedes the Convention's provisions for treaty abuse: a benefit shall not be granted if it is reasonable to conclude that obtaining the benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit aligns with the object and purpose of the relevant treaty provisions.
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