Principal Purposes Test prevents treaty benefits when obtaining them was a principal purpose, unless consistent with treaty object. The Multilateral Instrument replaces Article 30 with a Principal Purposes Test: a treaty benefit shall not be granted for an item of income if it is ... Summary
Principal Purposes Test prevents treaty benefits when obtaining them was a principal purpose, unless consistent with treaty object.
The Multilateral Instrument replaces Article 30 with a Principal Purposes Test: a treaty benefit shall not be granted for an item of income if it is reasonable to conclude that obtaining that benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit would be in accordance with the object and purpose of the relevant treaty provision.
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