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of <h1>Principal Purposes Test replaces Article 28A in DTAA with Poland, targeting treaty abuse and ensuring benefits align with objectives.</h1> Article 28A of the Double Taxation Avoidance Agreement (DTAA) with Poland, which limited benefits to residents or transactions primarily created to obtain treaty benefits, has been replaced by Article 7 of the Multilateral Instrument (MLI). The new provision, known as the Principal Purposes Test, denies treaty benefits if it is reasonable to conclude that one of the principal purposes of an arrangement or transaction was to obtain such benefits, unless granting them aligns with the treaty's objectives. This change aims to prevent treaty abuse by ensuring benefits are granted only when consistent with the treaty's purpose.
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