CRA treats ss. 247(2)(b) and 245(2) the same for MAP procedure purposes

Given that both are viewed as domestic anti-avoidance provisions, CRA will follow the same MAP approach to s. 247(2)(b) as with GAAR, i.e., if it is a primary position of the CRA that 247(2)(b) applies then, as with GAAR assessments, Canada will simply present that position to the other Competent Authority and, if there is double-taxation, seek relief from the other country - rather than giving up the assessment.

Neal Armstrong. Summary of 15 September 2020 IFA Roundtable, Q.3 under s. 247(2)(b).