S.224(1) only creates the right in the Crown to demand payment of a debt and does not give the Crown a priority. "The crown simply acquires a debt like any other although that is subject to the settled principle of law that claims and debts of the Crown have priority over other creditors of equal degree."
The Minister of National Revenue was held to rank pari passu with the Saskatchewan Minister of Finance with respect to moneys paid by a garnishee of both into Court, notwithstanding that the s. 224 demand of the federal minister was made 10 days later than the demand by the Saskatchewan Minister under a provincial statutory equivalent of s. 224.