No, the provision that is in the multilateral instrument is a provision that would allow for treaty benefits in certain circumstances where a transparent entity exists. It would clarify those situations. It would also provide for benefits when that transparent entity is in a third jurisdiction, not in one of the two contracting states. In our view, that can lead, in certain circumstances, to an inappropriate grant of treaty benefits as a result of this third jurisdiction having a transparent entity. Our view is that it should be limited to entities in one of the two contracting states.
To my knowledge, the CRA has not had significant issues with transparent entities, except in the context of the United States. We also don't see that it's a situation where there is a strong need for such a provision. To the extent there were a need for such a provision, we would have to bilaterally negotiate with the other state to include that provision.