Principal purposes test: Denies treaty benefits where obtaining the benefit was a principal purpose, unless consistent with object and purpose. Article 29 of the UAE DTAA is replaced by paragraph 1 of Article 7 of the MLI: a resident entity is not entitled to treaty benefits if the main purpose, or one of the main purposes, of its creation was to obtain benefits under the Agreement that would not otherwise be available, including entities lacking bona fide business activities; Article 7 applies a Principal Purposes Test denying benefits where obtaining the benefit was one of the principal purposes of arrangements or transactions, unless granting the benefit aligns with the object and purpose of the relevant 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 where obtaining the benefit was a principal purpose, unless consistent with object and purpose.
Article 29 of the UAE DTAA is replaced by paragraph 1 of Article 7 of the MLI: a resident entity is not entitled to treaty benefits if the main purpose, or one of the main purposes, of its creation was to obtain benefits under the Agreement that would not otherwise be available, including entities lacking bona fide business activities; Article 7 applies a Principal Purposes Test denying benefits where obtaining the benefit was one of the principal purposes of arrangements or transactions, unless granting the benefit aligns with the object and purpose of the relevant provisions.
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