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of <h1>Diplomatic Privileges Unaffected by DTAA; MLI Imposes Anti-Abuse Rules and Principal Purposes Test for Treaty Benefits</h1> Article 29 of the Double Tax Avoidance Agreement (DTAA) between Ukraine and another contracting state addresses the fiscal privileges of diplomatic and consular officials, ensuring they remain unaffected by the convention. Article 10 of the Multilateral Instrument (MLI) introduces anti-abuse rules for permanent establishments in third jurisdictions, restricting treaty benefits if the third jurisdiction's tax rate is significantly lower. Exceptions exist if the income is related to active business operations. Article 7 of the MLI includes a Principal Purposes Test to prevent treaty abuse, denying benefits if the primary purpose of a transaction was to obtain such benefits, unless justified by the treaty's objectives.
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