R. v. Melford Developments Inc., 82 DTC 6281, [1982] CTC 330, [1982] 2 SCR 504 -- summary under Subsection 214(15)

In the absence of this provision, "interest" in Part XIII would refer primarily to "the payment of rent by a borrower for the use of the principal of the lender to whom the rent is paid". However, in the absence of the overriding effect of any Convention, the effect of s. 214(15) is to convert guarantee fees into "interest" for the purpose of the withholding tax provisions of that Part.