CRA indicates that it will be guided by the OECD examples in applying the PPT

The OECD provided various examples on the application of the principal purpose test (PPT) in the MLI. CRA noted that no comments or reservations were made by Canada regarding those examples, and it will look at those examples for guidance in interpreting the PPT.

To date, no ruling requests on the PPT have been received.

Neal Armstrong. Summary of 27 October 2020 CTF Roundtable, Q.6 under Treaties – MLI – Art. 7(1).