CRA is establishing a “TAP” Committee, similar to the GAAR Committee, to address PPT issues

CRA is establishing a new “Treaty Abuse Prevention Committee” (the “TAP Committee”), which will be in charge of making recommendations on the application or non-application of the principal purpose test in the MLI. It will be staffed in a similar manner to the GAAR Committee (i.e., also including Finance and Justice representatives) and run in a similar manner. Where a s. 245(1) “tax benefit” emanates from a bilateral treaty, the TAP Committee is charged with considering both the PPT and GAAR, thereby taking over GAAR responsibility from the GAAR Committee in this Treaty context.

Neal Armstrong. Summary of 3 December 2019 CTF Roundtable, Q.1 under Treaties – MLI – Art. 7(1).