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 ... Summary
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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