Principal Purpose Test limits treaty benefits when obtaining them was a principal purpose, preserving diplomatic fiscal privileges. Fiscal privileges of diplomatic and consular officials remain unaffected by the DTAA, preserving entitlements under international law and special agreements. The MLI's Principal Purpose Test applies and supersedes conflicting treaty provisions: treaty benefits may be denied where obtaining the benefit was one of the principal purposes of an 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 limits treaty benefits when obtaining them was a principal purpose, preserving diplomatic fiscal privileges.
Fiscal privileges of diplomatic and consular officials remain unaffected by the DTAA, preserving entitlements under international law and special agreements. The MLI's Principal Purpose Test applies and supersedes conflicting treaty provisions: treaty benefits may be denied where obtaining the benefit was one of the principal purposes of an arrangement, unless granting the benefit aligns with the object and purpose of the relevant treaty provision.
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