Regarding the deduction of interest on a non-interest bearing debt issued at a discount, CCRA stated:
Where there is no stipulated interest payable, the provisions of subsection 16(1) may apply to such contracts with the result that an amount is deemed to be interest on a debt obligation to the investor and the issuer. Since subsection 16(1) refers to an amount under a contract rather than a payment, interest is deductible based on the amount paid or payable. It should be noted, however, that such contracts with maturities of more than one year are considered to provide for both simple interest (deductible on the basis of the amount paid or payable) and compound interest (deductible only on the basis of the amount paid).