CRA acknowledges that what is “nominal property” for purposes of the ETA s. 156 election can be determined on a relative basis

The test of who is a “qualifying member” eligible to make an ETA s. 156 election for intra-group supplies to occur at deemed nil consideration references whether substantially all the registrant’s property (other than financial instruments and “property having a nominal value”) has been acquired for consumption, use or supply exclusively in the course of its commercial activities (para. (c)(i)) or, if it has no such property, instead references the services it supplies (para. (c)(ii)) or its reasonably expected prospective supplies and purchases (para. (c)(iii)).

CRA stated that generally this test “will be made with reference to the value of the property and its significance, relative to the commercial activity in question,” so that (to use the extreme example cagily provided by CRA) a $300 computer would be nominal relative to a business with a prospective $1 billion in assets.

Neal Armstrong. Summary of 24 April 2015 Interpretation 166609 under ETA s. 156(1) – qualifying member.