New Harmonized Value-Added Tax System Regulations

Section 11

Administrative Policy

12 July 2023 GST/HST Ruling 174441 - and GST/HST INTERPRETATION - Application of GST/HST on funds raised through crowdfunding

A Canadian corporate registrant (“X”) raises money to fund a project through a crowdfunding website from supporters around the world. By their...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(c) - Subparagraph 142(1)(c)(i) if no contractual restrictions on place of use of IPP, the IPP is supplied in Canada 203
Tax Topics - Excise Tax Act - Section 223 - Subsection 223(1) factors relevant to determining whether GST inclusive or exclusive 59
Tax Topics - Excise Tax Act - Section 133 s. 133 effectively deemed advance payments to be consideration for a taxable supply 117

Section 6

Subsection 6(1)

Administrative Policy

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 35

Conference example

ABC Co hosts a two day conference on the latest developments within a particular field and engages various experts to present...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 17 fee for training session or seminar was for IPP 253

Revenu Quebec "Place of Supply"

The place of supply determines whether the HST or the GST and QST apply. ...For more information on the application of the GST/HST, refer to...

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17 January 2013 Ruling Case No. 130479

Members of a national organization (who provide their business address) pay annual fees for membership and separate fees for admissions to...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 8 contracting address referenced 50

Section 7

Administrative Policy

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"

Meaning of "can only be used"

The terms of the agreement for the supply governing the use of the rights generally determine the extent, if any, to...

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Section 8

Administrative Policy

17 January 2013 Ruling Case No. 130479

Members of a national organization (who provide their business address) pay annual fees for membership and separate fees for admissions to...

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13 June 2011 Headquarters Letter Case No. 133042

a supply of intangible personal property that can be used anywhere in Canada which is made by a non-resident supplier to a Canadian-resident...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule IX - Part II - Section 1 place of legal delivery, e.g., under Incoterms, is referenced 107
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(a) Incoterm delivery terms 107

18 May 2011 Headquarters Letter Case No. 123947

a resort developer supplies memberships that entitle a member to use certain real property at one or more resort locations located in Canada and...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(c) points to use resort units could be IPP or real property rights 128

18 April 2011 Headquarters Letter Case No. 123466

the supply of memberships in an association would be governed by s. 8 as a supply of intangible personal property so that, for example, if in the...

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Paragraph 8(b)

Administrative Policy

23 November 2011 Ruling Case No. 131828

The supplier of specified time memberships to a social networking website does not obtain a home or business address of the recipients of the...

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CBAO National Commodity Tax, Customs and Trade Section – 2011 GST/HST Questions for Revenue Canada, Q. 5

A Co is selling to B Co assets of a portion of its service/repair business which it carries on in Quebec and Ontario including goodwill (mostly, a...

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Section 10

Administrative Policy

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"

Ontario situs even though TPP predominantly in the U.S.

Example 72
A registered non-resident company supplies an Ontario company with intangible...

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Subsection 13(1)

See Also

Rochus Geissel, as liquidator of RGEX GmbH v Finanzamt Neuss (Neuss Tax Office), C 374/16, [2017] BVC 58 (European Court of Justice, 5th Chamber)

The Neuss Tax Office in Germany denied input tax claims of RGEX (which traded in motor vehicles) on its purchase of 122 motor vehicles on the...

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Words and Phrases
address
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 3 - Paragraph 3(a) policy met where registration of vendor can be verified 75

Administrative Policy

16 February 2016 Ruling 165366 Dietetic Services

A dietician who is registered with the provincial College of Dietitians entered into a Service Agreement with a registered charity (the...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Qualifying Health Care Supply nutiritional consulting by licensed dietician not excluded 152
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 7.1 nutritional consulting supplied to registered charity exempted 32

5 February 2016 Interpretation 153241

CRA considered that independent medical evaluations (IMEs) supplied by non-employee doctors to insurance companies or lawyers after March 21,...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 5 pre-2013 medical evauations for insurers generally exempt 274
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Qualifying Health Care Supply medical evaluations for insurers now excluded 294
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(g) doctor provided single supply of medical evaluation service to insurer so that all of fee taxable notwithstanding report writing outside Canada 341

3 February 2014 Interpretation 126057

A registered non-resident (Company A) supplies services to X, many of whom have members which are located in various provinces and which have...

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31 October 2011 Ruling Case No. 132350

A personnel services company (the Corporation) provides temporary and permanent staffing needs of its customers. Client 1 contracts with the...

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June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"

Includes:

  • Example 92 (the BC office of a corporation which receives the advice and had meetings with the advisor has a closer connection than the...

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Section 14

Administrative Policy

12 December 2012 Interpretation Case No. 142112

A real estate broker based in Nova Scotia is hired by a company with a head office in Nova Scotia to lease real property in New Brunswick to a...

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Words and Phrases
in relation to

Section 15

Administrative Policy

16 March 2016 Ruling 158766

After ruling that “each [on-site and off-site] supply of [Service X] made by [ACo] is a service in relation to TPP that is made in the province...

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June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"

Includes:

  • Example 104 (a pet is tangible personal property, so that a veterinary service is made in the province where the pet is...

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Section 16

Administrative Policy

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 23. ("HST Place of Supply Rules – Legal Services")

A GST/HST-registered Canadian law firm performs legal services, as a single, bundled supply, on behalf of a Canadian lender in a secured financing...

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Section 17

Administrative Policy

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 35

Conference example

ABC Co hosts a two day conference on the latest developments within a particular field and engages various experts to present...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 6 - Subsection 6(1) fee for training session or seminar was for IPP 256

Section 20

Stopover

Administrative Policy

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019

Round trip by ground back to Canada has no stopover if less than 24 hours

17. When determining the province in which the supply is made, a...

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Section 21

Administrative Policy

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019

Rule of origin

61. Generally, where the origin is specified on the ticket or voucher issued in respect of the first passenger transportation...

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Section 22

Subsection 22(1)

Administrative Policy

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019

Application where rail pass can only be used in Ontario (para. 74)

Example 19

An individual resident of Ontario purchases a rail pass at a rail...

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Section 23

Administrative Policy

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019

Different tax rate on each leg of journey (para. 76)

Example 20

A traveller buys an airline ticket for travel from St. John’s, Newfoundland and...

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Section 27

Administrative Policy

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"

'The time when the administrative litigation commences will normally be based on the procedural requirements imposed by the relevant legislation,...

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Section 28

Administrative Policy

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 35

Conference example

ABC Co hosts a two day conference on the latest developments within a particular field and engages various experts to present...

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June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"

Includes Example 120 (the provision of lighting and other special effects at a gala event event in Quebec is considered to be services performed...

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