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of <h1>Double Tax Avoidance Agreement with Korea: Article 28 Limits Benefits, Aligns with MLI's Principal Purposes Test to Prevent Tax Evasion.</h1> Article 28 of the Double Tax Avoidance Agreement (DTAA) with Korea addresses the limitation of benefits to prevent tax avoidance or evasion. It allows Contracting States to apply their laws to counteract tax avoidance. The original provision denying treaty benefits if the primary purpose was tax avoidance has been replaced by Article 7 of the Multilateral Instrument (MLI), which introduces a principal purposes test. This test denies benefits if obtaining them was a principal purpose of an arrangement, unless it aligns with the treaty's objectives. Additionally, residents controlled by non-residents or created to exploit treaty benefits are denied benefits under specific articles.
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