https://www.taxtmi.com/acts?id=45336 Diplomatic and consular fiscal privileges are preserved under international law and special agreements. The MLI modifies the Convention: its anti abuse rule for permanent establishments in third jurisdictions denies treaty benefits where income is treated as attributable to a third jurisdiction PE and taxed at substantially lower levels, subject to an active business exception and discretionary competent authority relief; the Principal Purposes Test denies benefits when obtaining a treaty advantage was a principal purpose unless consistent with the Convention's object and purpose. en-us Fri, 18 Oct 2024 12:01:46 +0530 Fri, 18 Oct 2024 12:01:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45336 Diplomatic and consular fiscal privileges are preserved under international law and special agreements. The MLI modifies the Convention: its anti abuse rule for permanent establishments in third jurisdictions denies treaty benefits where income is treated as attributable to a third jurisdiction PE and taxed at substantially lower levels, subject to an active business exception and discretionary competent authority relief; the Principal Purposes Test denies benefits when obtaining a treaty advantage was a principal purpose unless consistent with the Convention's object and purpose. Act-Rules DTAA Fri, 18 Oct 2024 12:01:46 +0530 https://www.taxtmi.com/acts?id=45336