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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 29 of DTAA with Luxembourg Updated by MLI Article 7 to Prevent Tax Evasion via Principal Purposes Test.</h1> Article 29 of the Double Tax Avoidance Agreement (DTAA) with Luxembourg addresses the limitation of benefits, emphasizing the prevention of tax evasion. The original provisions, which denied benefits to enterprises primarily created to obtain treaty advantages, have been replaced by Article 7 of the Multilateral Instrument (MLI). This new provision introduces the Principal Purposes Test, denying treaty benefits if obtaining them was a principal purpose of any arrangement or transaction, unless it aligns with the treaty's objectives. This aims to prevent treaty abuse by ensuring benefits are granted only when consistent with the agreement's intent.
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