Tax treaty benefits denied where obtaining the benefit was a principal purpose of the arrangement unless consistent with treaty purpose. Entitlement to treaty benefits is subject to a principal purpose test: a benefit will not be granted if it is reasonable to conclude that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted in the benefit, unless it is established that granting the benefit would be in accordance with the object and purpose of the relevant treaty provisions.
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.
Tax treaty benefits denied where obtaining the benefit was a principal purpose of the arrangement unless consistent with treaty purpose.
Entitlement to treaty benefits is subject to a principal purpose test: a benefit will not be granted if it is reasonable to conclude that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted in the benefit, unless it is established that granting the benefit would be in accordance with the object and purpose of the relevant treaty provisions.
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