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of <h1>UK-India Tax Treaty: Article 7 of MLI Introduces Purpose Test, Limits Benefits to Prevent Abuse Under DTAA.</h1> Article 28C of the Double Taxation Avoidance Agreement (DTAA) between the UK and another Contracting State limits benefits for residents whose primary purpose is to gain advantages under the Convention. If benefits are denied, the competent authority of the denying state must notify the other state. Article 7 of the Multilateral Instrument (MLI) replaces Article 28C, introducing a principal purposes test to prevent treaty abuse. Benefits are denied if obtaining them was a principal purpose of an arrangement, unless it aligns with the Convention's objectives. The UK and India interpret the application of Article 7 differently in relation to the Convention's provisions.
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