CRA indicates that it will not provide quick and crisp PPT guidance

When asked what weight CRA will accord to the examples in paras. 182 and 187 of the Commentary on Art. 29 of the 2017 OECD Model respecting the application of the principal purpose test in the Multilateral Instrument, CRA noted that Commentary bearing on these examples emphasized the importance of the facts and circumstances of each case, and CRA will apply the same case-by-case approach. When asked whether it could issue PPT rulings on an expedited basis, it indicated that it very well may need to consult other areas, which would suggests that the initial rulings instead may take some time.

Neal Armstrong. Summary of 16 May 2018 IFA Roundtable, Q.2 under Treaties – MLI - Art. 7(1).