[ compiled answer ]
law as at 14 Aug 2026 · settled
What does the MLI Article 12 principal-role test require?
The compiled answer
A person habitually plays the principal role leading to the conclusion of contracts that are routinely concluded without material modification by the enterprise — and the contracts are in the enterprise's name, or for transfer of its property, or for its services. It reaches negotiation-side conduct that the pre-BEPS conclude-contracts test misses. Among compiled pairs it operates only for India–Netherlands (from taxable periods beginning 1 April 2020 for non-WHT taxes).
Pinpoint
MLI Article 12(1), overlaying Article 5(5) India–Netherlands DTAA
String-verified quote
“habitually plays the principal role leading to the conclusion of contracts that are routinely concluded without material modification by the enterprise”
source: rule:PE.AGENCY.MLI-PRINCIPAL-ROLE.INNL — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/mli_principal_role_elements.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)