15 September 2020 IFA Roundtable Q. 3, 2020-0853371C6 - IFA 2020 Q3: Draft IC71-17R6, Paragraph 43 -- summary under Article 26

Given that both are viewed as domestic anti-avoidance provisions, CRA will follow the same MAP approach to s. 247(2)(b) (the transfer-pricing recharacterization rule) as with s. 245(2) (recharacterization of results under the general anti-avoidance rule), i.e., if it is a primary position of the CRA that 247(2)(b) applies then, as with GAAR assessments, Canada will simply present that position to the other Competent Authority and, if there is double-taxation, seek relief from the other country - rather than giving up the assessment.