granting of credit

When cardholders of credit cards issued by the appellant (RBC) used their cards for purchases from a foreign merchant, RBC would earn an “interchange fee” from the foreign bank (or other “merchant acquirer”) of the foreign merchant for accepting the charge.

The business of the subsidiaries of Vega International included the transport of commercial vehicles from the manufacturer to customer. International provided fuel cards to its subsidiaries which drivers used to purchase fuel, with International charging the subsidiaries on a monthly basis for the cost of the fuel plus a 2% surcharge.

In finding that International was not purchasing fuel and on-supplying the fuel to its subsidiaries, and instead was supplying credit to its subsidiaries (in this reference, its Polish subsidiary), the Court stated (at paras. 36, 44, 48):