Principal Purposes Test denies treaty benefits when obtaining the benefit was a main purpose, subject to object and purpose exception. Article 29 applies a Principal Purposes Test denying treaty benefits when obtaining those benefits was a principal purpose of an arrangement or transaction, unless consistent with the treaty's object and purpose, and incorporates the MLI's Simplified Limitation on Benefits framework defining 'qualified persons', an active conduct of a business exception, ownership based tests, competent authority discretionary relief, and related definitional rules.
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 the benefit was a main purpose, subject to object and purpose exception.
Article 29 applies a Principal Purposes Test denying treaty benefits when obtaining those benefits was a principal purpose of an arrangement or transaction, unless consistent with the treaty's object and purpose, and incorporates the MLI's Simplified Limitation on Benefits framework defining "qualified persons", an active conduct of a business exception, ownership based tests, competent authority discretionary relief, and related definitional rules.
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