https://www.taxtmi.com/acts?id=44805 The treaty's original Limitation of Benefits denied relief where obtaining treaty relief was a main purpose of persons creating or assigning income, with competent authorities allowed to consider factors like income nature, transaction circumstances, parties' intentions, and identity and control of legal or beneficial owners. That provision has been replaced by the MLI's Principal Purposes Test, which denies benefits when it is reasonable to conclude that securing the benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit aligns with the object and purpose of the relevant treaty provision. en-us Wed, 16 Oct 2024 15:09:26 +0530 Tue, 22 Oct 2024 14:14:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44805 The treaty's original Limitation of Benefits denied relief where obtaining treaty relief was a main purpose of persons creating or assigning income, with competent authorities allowed to consider factors like income nature, transaction circumstances, parties' intentions, and identity and control of legal or beneficial owners. That provision has been replaced by the MLI's Principal Purposes Test, which denies benefits when it is reasonable to conclude that securing the benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit aligns with the object and purpose of the relevant treaty provision. Act-Rules DTAA Wed, 16 Oct 2024 15:09:26 +0530 https://www.taxtmi.com/acts?id=44805