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15 May 2024 IFA Roundtable Q. 7, 2024-1007641C6- Principal Purpose Test in the Multilateral Instrument-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 application of PPT where Treaty-resident pure holdco with ultimate Treaty-resident parent received Canco dividends CRA was asked how the principal purpose test (PPT) in Art. 7(1) of the MLI) would apply in the situation where: Canco is wholly-owned by a Foreign Entity (FE) and FE is owned by a foreign multinational (Foreign MNC). ...