Before finding that a non-profit corporation providing low rental housing to indigent elderly persons qualified for exemption under the Act Respecting Municipal Taxation (Quebec) as a "reception centre", Gonthier J. summarized (at p. 5023) the relevant principles of interpretation:
The interpretation of tax legislation should follow the ordinary rules of interpretation;
- a legislative provision should be given a strict or liberal interpretation depending on the purpose underlying it, and that purpose must be identified in light of the context of the statute, its objective and the legislative intent;
- this is the teleological approach; the teleological approach will favour the taxpayer or the tax department depending solely on the legislative provision in question, and not on the existence of predetermined presumption;
- substance should be given precedence over form to the extent that this is consistent with the wording and objective of the statute;
- only a reasonable doubt, not resolved by the ordinary rules of interpretation, will be settled by recourse to the residual presumption in favour of the taxpayer.