Alberta Printed Circuits Ltd. v. The Queen, 2011 DTC 1177 [at at 967], 2011 TCC 232 -- summary under Article 26

Pizzitelli J. found (at [paras. 102-103) that the limitation periods in Articles IX(3) and XXVII(3) of the Canada-Barbados Tax Treaty did not apply because the taxpayer was a Barbados International Business Company, which Article XXX expressly excludes from application of the Treaty. He also noted (at para. 104) that given that Article IX(2) and (3) dealt specifically with transfer pricing adjustments "one must question the applicability of another, more general limitation period found in a different part of the Treaty, such as Article XXVII(3), especially where that other limitation period is similar."