A Canadian airline ("CAIL") entered into an agreement with the appellant ("RBC") to promote use of RBC's credit card and to honour frequent flyer points to be awarded by it to RBC at the rate of one Point for every dollar of qualifying credit spending. In finding that such payments by RBC were the consideration for a taxable supply by CAIL of Points, Hershfield J stated (at para. 28):
Everything CAIL did from being involved in establishing the terms of the credit facility to advertising the program was to promote the use of the card by the issuance of Points and that is what it was paid for – the issuance of Points.
By contrast, in Customs and Excise Commissioners v. Civil Service Monitoring Association, [1998] BVC 21 (Eng. CA), where the participation of an automobile association in a credit card program was found to be exempt because the association was involved in the design and operation of the program, "the substantive element and real character of the supply…was to arrange favourable, special credit terms and benefits for its members from the financial institutions granting the credit facility….[and] there was no other supply, like a supply of Points" (para. 35).