https://www.taxtmi.com/highlights?id=85188 CBDT issued guidance on applying the Principal Purpose Test under India's DTAAs, effective from MLI's entry into force on October 1, 2019. The PPT provision enables denial of treaty benefits where obtaining such benefits was a principal purpose of any arrangement, unless aligned with the DTAA's object and purpose. The guidance clarifies prospective application timeframes - from the effective date for bilateral PPTs, and as per MLI Article 35 for MLI-modified treaties. Notably, existing grandfathering provisions in Cyprus, Mauritius and Singapore DTAAs remain outside PPT's scope. Tax authorities may reference BEPS Action 6 Report and UN Model Tax Convention Commentary for case-specific application, subject to India's reservations. en-us Sat, 25 Jan 2025 16:20:36 +0530 Sat, 25 Jan 2025 16:20:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=85188 CBDT issued guidance on applying the Principal Purpose Test under India's DTAAs, effective from MLI's entry into force on October 1, 2019. The PPT provision enables denial of treaty benefits where obtaining such benefits was a principal purpose of any arrangement, unless aligned with the DTAA's object and purpose. The guidance clarifies prospective application timeframes - from the effective date for bilateral PPTs, and as per MLI Article 35 for MLI-modified treaties. Notably, existing grandfathering provisions in Cyprus, Mauritius and Singapore DTAAs remain outside PPT's scope. Tax authorities may reference BEPS Action 6 Report and UN Model Tax Convention Commentary for case-specific application, subject to India's reservations. Highlights Income Tax Sat, 25 Jan 2025 16:20:36 +0530 https://www.taxtmi.com/highlights?id=85188