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of <h1>Article 27 of DTAA with Malta Replaced by MLI Article 7, Introducing Principal Purposes Test to Combat Tax Evasion.</h1> Article 27 of the Double Taxation Avoidance Agreement (DTAA) with Malta addresses the limitation of benefits to prevent tax evasion. Initially, it stated that benefits would not be available if the main purpose of a transaction was to obtain treaty benefits. However, this was replaced by Article 7 of the Multilateral Instrument (MLI), which introduces a Principal Purposes Test. Under this test, treaty benefits are denied if it is reasonable to conclude that obtaining such benefits was a principal purpose of any arrangement, unless it aligns with the treaty's objectives.
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