Tax Notes International, January 10, 2022, p. 147
Establishing the object and purpose of tax treaty provisions lies at the heart of applying antiabuse rules, such as general antiavoidance rules under domestic law and the principal purpose test (PPT) in tax treaties. Tax planning arrangements like treaty shopping, designed to obtain treaty benefits, are not abusive unless they contravene the object and purpose of the provisions relied upon by the taxpayer.
Li, Jinyan, "Finding the Purpose of Tax TreatyProvisions Under GAAR: Lessons From Alta Energy" (2022). Articles & Book Chapters. 2882.