{"url":"https://lrlabs.ai/t/mli_principal_role_elements","engine":"deterministic","llm_in_path":false,"id":"mli_principal_role_elements","question":"What does the MLI Article 12 principal-role test require?","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","confidence":"settled","as_at":"14 Aug 2026","quote":"habitually plays the principal role leading to the conclusion of contracts that are routinely concluded without material modification by the enterprise","quote_string_verified":true,"quote_source":"rule:PE.AGENCY.MLI-PRINCIPAL-ROLE.INNL"}