Certainly this measure tries to curtail the ability of multinational groups to engage in what's commonly referred to as foreign affiliate dumping.
As I was indicating in the discussion about transfer pricing, that involves amounts paid out of Canada to a non-resident shareholder of a Canadian corporation. That generally attracts part XIII withholding tax.
There are a number of strategies that have developed to allow Canadian companies to buy foreign affiliates, perhaps from a non-resident parent company. Purchasing that foreign affiliate can be done either by way of debt or by way of cash assets in the Canadian corporation.
The acquisition cost of that or the interest paid in respect of the debt of the acquisition might go out on a basis that's not subject to part XIII withholding tax. It being a foreign affiliate, if it's running particular types of income, it might come back to Canada tax-free, so there might not be any Canadian tax.
It's a measure to deal with a particular form of international tax planning that seeks to take money out of the Canadian tax net.