CRA indicates that medical escort services can be exempted but not zero-rated
A company provided medical repatriation services, which involved arranging to transport an individual (the patient) from a foreign hospital to a health care facility in the individual’s home country. This would include transport between the medical facilities and airports via ground transportation (ambulance, taxi, or limo), and commercial airline transportation in the company of a medical escort (registered nurses, physicians and advanced cardiac life support trained paramedics). The company charged a daily rate for the medical escort and a fee for the medical equipment required by the patient.
CRA found that the company was making a single supply under the single supply doctrine, and that such supply did not qualify as a zero-rated “ambulance” service. However, it could qualify as an exempt nursing supply under Sched. V, Pt, II, s. 6 or an exempt physician supply under Sched. V, Pt, II, s. 5, depending on who accompanied the patient – whereas if the attendants were paramedics it would not be exempted.
It is unclear to what extent CRA was accepting that a single supply can be exempted if it has significant elements from two separately enumerated exempt items (nurses and physicians) - and that if these exempt elements were present, the exemption would not be tainted by the presence of paramedics.