Principal Purposes Test: treaty benefits denied when obtaining them was a principal purpose, while diplomatic fiscal privileges remain unaffected. Article 28 maintains that fiscal privileges of diplomatic and consular members under international law or special agreements are unaffected by the Cyprus DTAA. The MLI Article 7 Principal Purposes Test applies and supersedes conflicting treaty provisions: a benefit will not be granted if obtaining it was one of the principal purposes of the arrangement, unless granting the benefit accords with the object and purpose of the relevant treaty provision.
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: treaty benefits denied when obtaining them was a principal purpose, while diplomatic fiscal privileges remain unaffected.
Article 28 maintains that fiscal privileges of diplomatic and consular members under international law or special agreements are unaffected by the Cyprus DTAA. The MLI Article 7 Principal Purposes Test applies and supersedes conflicting treaty provisions: a benefit will not be granted if obtaining it was one of the principal purposes of the arrangement, unless granting the benefit accords with the object and purpose of the relevant treaty provision.
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