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.
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 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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