In the context of an extended discussion of the principles of statutory interpretation relevant to taxing statutes (in this instance, the Act Respecting Municipal Taxation (Quebec), Gonthier J. stated (p. 15):
"According to the general rule which provides that the burden of proof lies with the plaintiff, in any proceeding it is for the party claiming the benefit of a legislative provision to show that he is entitled to rely on it. The burden of proof thus rests with the tax department in the case of a provision imposing a tax obligation and with the taxpayer in the case of a provision creating a tax exemption."