Principal Purposes Test restricts treaty benefits where obtaining those benefits was a principal purpose of the arrangements. The Estonia DTAA preserves domestic anti avoidance provisions and applies the MLI's Principal Purposes Test, which denies treaty benefits when obtaining those benefits was one of the principal purposes of an arrangement or transaction unless granting the benefit accords with the object and purpose of the relevant treaty provision, and provides for competent authority notification when benefits are denied.
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 restricts treaty benefits where obtaining those benefits was a principal purpose of the arrangements.
The Estonia DTAA preserves domestic anti avoidance provisions and applies the MLI's Principal Purposes Test, which denies treaty benefits when obtaining those benefits was one of the principal purposes of an arrangement or transaction unless granting the benefit accords with the object and purpose of the relevant treaty provision, and provides for competent authority notification when benefits are denied.
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