https://www.taxtmi.com/circulars?id=68070 The guidance explains that the Principal Purpose Test permits denial of treaty benefits where, on an objective assessment of all relevant facts, obtaining the benefit was one of the principal purposes of an arrangement, unless it is established that granting the benefit accords with the object and purpose of the relevant treaty provision; it instructs that the PPT is to be applied prospectively, specifies interaction rules for bilateral incorporations and MLI incorporation timing, and excludes certain treaty-specific grandfathering provisions from the PPT while endorsing a context-specific, fact-based assessment with reference to BEPS Action 6 and the UN Model Commentary as supplementary guidance. en-us Tue, 21 Jan 2025 00:00:00 +0530 Thu, 23 Jan 2025 11:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=68070 The guidance explains that the Principal Purpose Test permits denial of treaty benefits where, on an objective assessment of all relevant facts, obtaining the benefit was one of the principal purposes of an arrangement, unless it is established that granting the benefit accords with the object and purpose of the relevant treaty provision; it instructs that the PPT is to be applied prospectively, specifies interaction rules for bilateral incorporations and MLI incorporation timing, and excludes certain treaty-specific grandfathering provisions from the PPT while endorsing a context-specific, fact-based assessment with reference to BEPS Action 6 and the UN Model Commentary as supplementary guidance. Circulars Income Tax Tue, 21 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/circulars?id=68070