In finding that it was appropriate to apply, in interpreting a Quebec Taxation Act provision, the interpretation that had been accorded in Vancouver Metal Arts to the similar federal provision on which the Quebec provision had been modelled, the Court stated (at paras. 46, 48, TaxInterpretations translation):
[T]he legislature … clearly wished to favour a harmonization in this regard between the Quebec and federal tax regimes. An interpretation of TA section 250.3 that differed from that of its federal equivalent in ITA subsection 39(5) would derogate from this legislative objective. …
[I]n tax matters, where the federal and provincial provisions are appreciably in the same form, a presumption of coherence between the two provisions should prevail.