Prevention of treaty abuse limits treaty benefits when obtaining the benefit was a principal purpose, subject to object and purpose exception. Article 28 preserves diplomatic fiscal privileges, ensuring Convention provisions do not affect tax immunities of diplomatic and consular personnel under international law or special agreements. Paragraph 1 of Article 7 of the MLI applies and supersedes incompatible Convention provisions: a Convention benefit may be denied where obtaining that benefit was one of the principal purposes of an arrangement or transaction, unless granting it would be consistent with the object and purpose of the relevant Convention 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.
Prevention of treaty abuse limits treaty benefits when obtaining the benefit was a principal purpose, subject to object and purpose exception.
Article 28 preserves diplomatic fiscal privileges, ensuring Convention provisions do not affect tax immunities of diplomatic and consular personnel under international law or special agreements. Paragraph 1 of Article 7 of the MLI applies and supersedes incompatible Convention provisions: a Convention benefit may be denied where obtaining that benefit was one of the principal purposes of an arrangement or transaction, unless granting it would be consistent with the object and purpose of the relevant Convention provision.
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