Global Cash Access - Federal Court of Appeal applies "commercial efficacy" (rather than Marxist labour theory of value) approach to find that mostly clerical services were a financial supply for GST purposes

Global Cash Access, which arranged for cash advances from credit card issuers to the patrons of casinos, paid a fee to the casino, which provided space for Global's terminals (which were used to approve the transactions) as well as preparing a sort of cheque that the patron cashed in at the casino cashier.  Although from CRA perspective (which you might label as following Marx's labour theory of value), what the casino was mostly getting paid for was its clerical services and the provision of the space, Sharlow JA found that the "commercial efficacy" of the whole arrangement turned on the provision of the cash by the casino, so that the fee was consideration for a single supply of a financial service.

This same approach (that what was really being paid for was the "cheque" cashing function, even though that part of it was easy) also dictated a conclusion that the clerical/space provision aspects were not the "predominant" element of what was being supplied, so that the exclusions in paras. (r.4) and (r.5) of the financial services definition did not apply.  This, in turn, suggests that these exclusions, which seemed like a big deal when they were introduced, may be benign.

Neal Armstrong.  Summary of Global Cash Access (Canada) Inc. v. Canada, 2013 FCA 269, under ETA - s. 123(1) - "financial service."