https://www.taxtmi.com/acts?id=45501 Article 29 preserves fiscal privileges of diplomatic or consular officials. It provides that paragraphs 1-3 of MLI Article 10 apply and supersede the Convention, denying treaty benefits where income is treated as attributable to a permanent establishment in a third jurisdiction and tax there is materially lower, subject to an active business exception and competent authority discretion to grant benefits after consultation. It further applies paragraph 1 of MLI Article 7 (Principal Purposes Test) to deny benefits when obtaining them was a principal purpose of arrangements, unless consistent with the Convention's object and purpose. en-us Fri, 18 Oct 2024 15:08:30 +0530 Fri, 18 Oct 2024 15:08:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45501 Article 29 preserves fiscal privileges of diplomatic or consular officials. It provides that paragraphs 1-3 of MLI Article 10 apply and supersede the Convention, denying treaty benefits where income is treated as attributable to a permanent establishment in a third jurisdiction and tax there is materially lower, subject to an active business exception and competent authority discretion to grant benefits after consultation. It further applies paragraph 1 of MLI Article 7 (Principal Purposes Test) to deny benefits when obtaining them was a principal purpose of arrangements, unless consistent with the Convention's object and purpose. Act-Rules DTAA Fri, 18 Oct 2024 15:08:30 +0530 https://www.taxtmi.com/acts?id=45501