Grand Toys Ltd. v. MNR, 90 DTC 1059, [1990] 1 CTC 2165 (TCC) -- summary under Paragraph 212(1)(d)

The taxpayer agreed to act as the exclusive distributor in Canada of articulated figurines produced by a Hong Kong joint venture ("Panosh") and agreed to pay, for each order it placed, 103% of the ex Hong Kong factory price, plus "a buying commission and royalty ... of U.S. $0.52". Because the "royalty" was in no way related to the taxpayer's profits or gross sales of the units, and because there was no element of contingency in the quantum of the payments to be made, it did not constitute a payment in the nature of rents, royalties or similar payments.