Principal purpose test restricts treaty benefits where obtaining the benefit was a principal purpose, unless aligned with treaty object. A benefit under the Agreement shall not be granted if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit would be in accordance with the object and purpose of the relevant provisions of the Agreement.