Principal Purposes Test denies treaty benefits if obtaining them was a main purpose, unless consistent with treaty object. Domestic anti-evasion provisions remain operative. The MLI's Principal Purposes Test replaces the treaty's prior limitation clauses and denies treaty benefits for an item of income if, considering all relevant facts and circumstances, obtaining the benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit is consistent with the object and purpose of the relevant treaty provisions.
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 if obtaining them was a main purpose, unless consistent with treaty object.
Domestic anti-evasion provisions remain operative. The MLI's Principal Purposes Test replaces the treaty's prior limitation clauses and denies treaty benefits for an item of income if, considering all relevant facts and circumstances, obtaining the benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit is consistent with the object and purpose of the relevant treaty provisions.
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