What factors would the CCRA consider in determining whether the amount of interest payable under a particular loan agreement exceeds a "reasonable amount in respect thereof"? CCRA responded:
The interest deduction under paragraph 20(1)(c) is the lesser of the amount paid or payable and a reasonable amount. As stated in Shell, "[w]here an interest rate is established in a market of lenders and borrowers acting at arm’s length from each other, it is generally a reasonable rate… ". In assessing whether or not an interest rate is reasonable, one must take into account comparable market rates for similar market risks and terms and the existence of issue premiums.