Principal Purposes Test denies treaty benefits when obtaining them was a principal purpose, subject to object and purpose consistency. Limitation on treaty benefits is governed by domestic anti evasion rules and the Multilateral Instrument's Principal Purposes Test, which denies a treaty benefit where it is reasonable to conclude that obtaining the benefit was one of the principal purposes of the arrangement or transaction producing it, unless granting the benefit would be consistent 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 denies treaty benefits when obtaining them was a principal purpose, subject to object and purpose consistency.
Limitation on treaty benefits is governed by domestic anti evasion rules and the Multilateral Instrument's Principal Purposes Test, which denies a treaty benefit where it is reasonable to conclude that obtaining the benefit was one of the principal purposes of the arrangement or transaction producing it, unless granting the benefit would be consistent with the object and purpose of the relevant treaty provision.
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