Miedzi Copper – Tax Court of Canada finds that a Holdco was able to claim ITCs as if it were an Opco

A holding company whose only significant activity was financing its Lux sub which, in turn, financed exploration companies in Poland, was entitled to full input tax credits for the GST on all the fees charged to it by its executives (who were independent contractors rather than employees) and by professional firms. Paris J indicated that ETA ss. 186(1)and (3) should be interpreted broadly in accordance with the intent that holding companies should be on the same footing as if they carried on the underlying commercial activities directly.

Neal Armstrong. Summary of Miedzi Copper Corporation, 2015 TCC 26, under ETA, s. 186(1).