Currently, Canada has not proposed to opt into article 3. Canada has a reservation in respect of the OECD model tax convention where such a provision is also contained. It was developed, generally speaking, by OECD member countries. It extends to include situations where there may be a transparent entity in a third jurisdiction.
In Canada's view, the provision would be better applied and could avoid some unintended effects if it applied only with respect to entities in the two contracting states. We have found, through our experience with the United States, that Canada has the most instances of transparent entities being relevant to transactions. To the extent there is an issue with a particular jurisdiction, it may be desirable to bilaterally negotiate such a provision for the situations particular to the two jurisdictions.