Principal purpose test bars treaty benefits if obtaining the benefit was a principal purpose, unless consistent with treaty object. Article 27 preserves fiscal immunities of diplomatic and consular officials under international law and special agreements. The Multilateral Instrument's Principal Purposes Test (Article 7 MLI) applies and supersedes the Agreement: treaty benefits may be denied where obtaining the benefit was a principal purpose of the arrangement, unless granting the benefit aligns with the object and purpose of the relevant treaty provision.
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 purpose test bars treaty benefits if obtaining the benefit was a principal purpose, unless consistent with treaty object.
Article 27 preserves fiscal immunities of diplomatic and consular officials under international law and special agreements. The Multilateral Instrument's Principal Purposes Test (Article 7 MLI) applies and supersedes the Agreement: treaty benefits may be denied where obtaining the benefit was a principal purpose of the arrangement, unless granting the benefit aligns with the object and purpose of the relevant treaty provision.
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