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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 28 of DTAA with Estonia Limits Benefits to Prevent Tax Evasion; MLI Introduces Principal Purposes Test.</h1> Article 28 of the Double Taxation Avoidance Agreement (DTAA) with Estonia addresses the limitation of benefits to prevent tax evasion or avoidance. It specifies that benefits of the agreement are not available if the main purpose of a resident's creation or transactions is to gain such benefits improperly. Legal entities without genuine business activities are also covered. The Multilateral Instrument (MLI) replaces certain provisions with the Principal Purposes Test, which denies treaty benefits if obtaining them was a principal purpose of an arrangement, unless it aligns with the agreement's objectives.
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