Commercial substance tests target artificial asset and investment routing used mainly to secure tax benefits.

An arrangement may be treated as lacking commercial substance where it involves the location of an asset, transaction or residence without any substantial commercial purpose other than obtaining a tax benefit. The commentary explains that artificial routing through an entity with no real business activity, round-tripping of funds, or use of an intermediary to access treaty advantages may indicate absence of commercial substance. Relevant indicators include lack of business risk, cash flow effect, and independent commercial purpose.

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