In my view, the two key aspects in this bill and in this convention are articles 6 and 7. Those are two of the rules that go towards preventing the abuse of tax treaties.
I think article 6 will be very important in helping our courts interpret our tax treaties and this anti-abuse rule, because it makes a clear statement endorsed by both treaty partners that, while the common intention is to eliminate double taxation, it's not to create opportunities for non-taxation or reduced taxation.
Article 7 itself contains the anti-abuse rule, and through Canada's choice and the choice of our treaty partners, all of the tax treaties that will be covered by the MLI will be updated to include a principal purpose test. The test provides that a treaty benefit shall not be granted if it's reasonable to conclude that the obtaining of the benefit was one of the principal purposes of an arrangement or transaction, unless the benefit is in accordance with the object and purpose of the relevant provisions of the convention. It provides protection against taxpayers using bilateral tax treaties to obtain benefits that were not intended for those particular taxpayers.