Principal purpose test restricts treaty benefits where obtaining them is a principal arrangement purpose, subject to an object-and-purpose exception. Article 27B restricts benefits under the Mauritius Comprehensive Agreement where obtaining a benefit was one of the principal purposes of an arrangement ... Summary
Principal purpose test restricts treaty benefits where obtaining them is a principal arrangement purpose, subject to an object-and-purpose exception.
Article 27B restricts benefits under the Mauritius Comprehensive Agreement where obtaining a benefit was one of the principal purposes of an arrangement or transaction that directly or indirectly produced it. A benefit may still be granted where doing so accords with the object and purpose of the relevant treaty provisions.
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