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of <h1>New Anti-Abuse Rules in Multilateral Instrument Limit Treaty Benefits for Low-Tax Jurisdictions, Ensure Fair Taxation Practices</h1> Article 27 of the Double Tax Avoidance Agreement (DTAA) with Austria states that diplomatic and consular officials retain fiscal privileges under international law or special agreements. Article 10 of the Multilateral Instrument (MLI) introduces an anti-abuse rule for permanent establishments in third jurisdictions, denying treaty benefits if the tax in that jurisdiction is significantly lower. Exceptions apply if the income is related to active business operations. Article 7 of the MLI prevents treaty abuse by denying benefits if the main purpose of a transaction was to obtain such benefits, unless it aligns with the treaty's objectives. Competent authorities may grant benefits if justified.
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