https://www.taxtmi.com/acts?id=45437 A Principal Purpose Test replaces the Convention's Limitation of Benefits rule: a treaty benefit shall not be granted if it is reasonable to conclude that obtaining the benefit was one of the principal purposes of any arrangement or transaction producing the benefit, unless granting the benefit accords with the object and purpose of the relevant treaty provisions. Where benefits are denied under this rule, the competent authority denying benefits shall notify the competent authority of the resident's State. Parties record a divergence on the textual placement and scope of this replacement in synthesised treaty texts. en-us Fri, 18 Oct 2024 14:24:46 +0530 Tue, 22 Oct 2024 17:47:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45437 A Principal Purpose Test replaces the Convention's Limitation of Benefits rule: a treaty benefit shall not be granted if it is reasonable to conclude that obtaining the benefit was one of the principal purposes of any arrangement or transaction producing the benefit, unless granting the benefit accords with the object and purpose of the relevant treaty provisions. Where benefits are denied under this rule, the competent authority denying benefits shall notify the competent authority of the resident's State. Parties record a divergence on the textual placement and scope of this replacement in synthesised treaty texts. Act-Rules DTAA Fri, 18 Oct 2024 14:24:46 +0530 https://www.taxtmi.com/acts?id=45437