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He further found that charges made by DTI at the end of each trip to the drivers of $0.76 per mile for fuel, and $0.08 per mile for vehicular maintenance, were consideration for an on-supply by DTI to the drivers of fuel and maintenance services. In finding that such fuel and diesel supplies were not consideration for a zero-rated supply by DTI, Russell J noted that such supplies were not part of the “freight transportation service” (“FTS”) made by each driver to DTI (given that the recipients of the diesel and maintenance supplies (the drivers) differed from the recipient of the FTS (i.e., DTI). ...

Bowie J stated (at para. 13): [O]nly an insurance company licensed to do so may sell insurance, and only a provincial government may sell motor vehicle licences… He also did not agree that separate consideration needed to be received for the insurance and licences, stating (at para. 14): I know of no reason that would prevent [Libra] from supplying its services as an agent to obtain licences and insurance along with other services for a single consideration. ...

The King, 2025 TCC 61-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence parol evidence could not be used to bifurcate a payment BC Hydro, which had entered into an electricity purchase agreement (EPA) with an independent power producer for the supply of electricity at a particular project in BC, agreed with that supplier that the EPA would be amended to provide, inter alia, that in consideration for the payment by BC Hydro of the sum of $8.5 million by the date 30 days after the project became operational, BC Hydro would have the option to extend the term of the EPA by a further 16 years. ... The Queen relied on such principles from Eli Lilly, stating that failing the finding of ambiguity in the document under consideration, it is not open to the Court to consider extrinsic evidence, furthermore, that even where there is ambiguity, evidence only of a party’s subjective intention is not admissible. ...

Canada, 2003 DTC 5225, 2003 FCA 128-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property "property" entails an exclusive right A portion of the consideration paid by a purchaser of shares of operating companies in which the taxpayer had been a significant shareholder (directly, or through holding companies) was allocated as consideration for his entering into non-compete agreements. ...

., under the WD Act) and thus came within the definition of consideration. He then stated (at para 119): Under paragraph (b) of the definition of recipient in subsection 123(1) of the GST Act, the MHS Stewards are deemed to be recipients of the supply since they were the persons who were liable to pay the consideration for the supply. ...

London Life acquired the construction inputs for the purpose of providing taxable supplies, i.e. leasehold improvements to its landlords for consideration, i.e. the tenant improvement allowances. ... But when the leasing transactions are considered independently, London Life is supplying the leasehold improvements to the landlords for the consideration of the leasehold improvement allowances. ...

Perram and Jackman JJ found that, since as a matter of contractual interpretation, all of the amounts paid by the Bottler to the Seller were consideration for the sold concentrate, none of such payments could be treated as a trademark royalty that was subject to Australian withholding tax. ... Accordingly, the Commissioner’s assessment of Australian withholding tax on a portion of the consideration was reversed. ...

Step 3: The CLCs then assigned the leases and their title in the cars to an offshore bank Soc Gen Jersey ("SGJ"), in consideration for £20m (financed by SG London, which received a further assignment of the assets as security). ... Respecting the first condition, Lord Sumption noted (at para. 14) that the VAT "broad principle is that tax on the ultimate value of the product is levied only once, albeit that it may be collected at different stages of the process of manufacture and distribution," and (at para. 20) that normally "the reseller seeking to avail himself of the margin scheme will have acquired the goods from someone with no right to recover input tax in respect of their own acquisition of them" so that "the object and effect is to avoid double taxation," whereas "the effect of the KPMG scheme was to enable the Pendragon Group to sell demonstrator cars second-hand under the margin scheme in circumstances where VAT had not only been previously charged but fully recovered…[so that a] system designed to prevent double taxation on the consideration for goods has been exploited so as to prevent any taxation on the consideration at all" (para. 30). ...

Before consideration of the "adventure" concept, the land was not inventory of a business. ... Furthermore, "a bona fide gift of land is not a transaction that can be described as being ‘in the nature of trade' if it is otherwise unconnected with a business" (para. 95), the deemed proceeds under s. 69(1)(c) could not be treated as consideration for this purpose (para. 103) and "the nature of the gift as a transfer of property for no consideration is not changed simply because there are favourable income tax consequences" (para. 101). ...

Hélie Holdco purchased 10.5% of the common shares of Amiante from Poulin for nominal consideration and purchased 388,861 Class D preferred shares from Turgeon for a purchase price of $388,861 in consideration for a note in that amount bearing interest at 4% and which was to be repaid out of 90% of the amounts received by Hélie Holdco from Amiante. ... In January 2014, Hélie Holdco transferred the balance of its Class D preferred shares to what now was the parent corporation of Amiante, without there being any evidence of consideration having been received for this transfer, and with the balance of the note remaining unpaid. ...