Before going on to indicate that it no longer imputed interest on mismatched cross-border swap payments, CRA stated:
As set out in various of its publications, the CRA considers that all amounts payable or receivable under the terms of a swap agreement are on account of income and are to be included or deducted under section 9. This is consistent with the CRA's long-standing position that payments under a swap agreement do not have a specific character for legal purposes. Thus, as a matter of law, payments under a swap agreement are not interest, dividends, rents, royalties or payments for services or proceeds of disposition, nor do they represent a substitute for a legal obligation to pay such amounts.