Despite previously describing the Ramsay principle as having ‘reached a state of well-settled maturity’, in Royal Bank of Canada the Supreme Court was divided on when and how the principle applies. One might infer that Ramsay is now restricted to tax avoidance cases, or limited to domestic legislation; a more palatable inference is that Ramsay was applicable yet had no effect, either because the treaty did not support a broader purposive interpretation, or because a realistic view of the facts did not require a departure from the contractual position. In either case, the decision leaves the state of the law unclear.