Is financial dependence of one party on another sufficient in itself to create a non-arm’s length relationship?
CRA stated:
As noted … in Keybrand and Aeronautic, the financial dependence of one party on the other could, depending on the facts and circumstances of the situation, demonstrate that the parties are not dealing with each other at arm's length at a particular time in respect of a particular transaction.
As to what constituted financial dependence, CRA stated: