CRA finds that a supply of a service may be made for GST/HST purposes by other than the service provider

A recent ruling illustrates an interpretive approach of CRA under which it can consider X to be the supplier of a service for GST and HST purposes even though none of the service actually is performed by X.

A for-profit corporation which charges the families of non-resident minor children a fee for arranging for them to study at a Canadian school district and to be billeted at Canadian families, and pays tuition directly to the school district, was found to be earning its fees (through non-resident agents) from the non-resident families as consideration for an exempt educational service.

Neal Armstrong.  Summary of  22 September 2011 Ruling 129475 under ETA, Sched. V, Part III, s. 9.