https://www.taxtmi.com/acts?id=45563 Limitation of benefits rules deny treaty advantages where a resident's creation, existence, or a transaction had as a main purpose obtaining those advantages. Article 28A barred benefits to non individual residents or to arrangements whose main purpose was benefit acquisition. Article 28A is replaced by the MLI's Principal Purposes Test: a treaty benefit shall not be granted where it is reasonable to conclude that obtaining the benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit accords with the object and purpose of the relevant treaty provisions. en-us Fri, 18 Oct 2024 16:54:55 +0530 Tue, 22 Oct 2024 18:31:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45563 Limitation of benefits rules deny treaty advantages where a resident's creation, existence, or a transaction had as a main purpose obtaining those advantages. Article 28A barred benefits to non individual residents or to arrangements whose main purpose was benefit acquisition. Article 28A is replaced by the MLI's Principal Purposes Test: a treaty benefit shall not be granted where it is reasonable to conclude that obtaining the benefit was one of the principal purposes of the arrangement or transaction, unless granting the benefit accords with the object and purpose of the relevant treaty provisions. Act-Rules DTAA Fri, 18 Oct 2024 16:54:55 +0530 https://www.taxtmi.com/acts?id=45563