How have the courts interpreted the terms of a Dealer Agreement in the context of an interest free financing arrangement?

The comments of Mr. Justice Marceau in his concurring judgment in Saskatchewan Wheat Pool v. The Queen, 85 D.T.C. 5034 (F.C.A.) seem applicable to this situation. He states at 5038: [emphasis added] Indeed, there is no ambiguity in the terms of the Dealer Agreements. Clearly, the equipment is held on consignment. The Respondent intended to obtain, and did in fact obtain, the benefit of the consignment arrangement, namely interest free financing of its business as an industrial equipment dealer. It cannot be allowed now to seek to recast the agreement as providing sufficient ownership interest in the equipment for additional tax benefits. Conclusions