Principal purpose test restricts treaty benefits where arrangements seek tax advantages unless granting benefits matches treaty purposes. Treaty benefits for an item of income may be refused under the principal purpose test where, on all relevant facts and circumstances, obtaining the ... Summary
Principal purpose test restricts treaty benefits where arrangements seek tax advantages unless granting benefits matches treaty purposes.
Treaty benefits for an item of income may be refused under the principal purpose test where, on all relevant facts and circumstances, obtaining the benefit was one of the principal purposes of an arrangement or transaction that directly or indirectly produced it. A benefit remains available if granting it accords with the object and purpose of the relevant treaty provisions.
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