CRA finds that a fee for an agreement to be available to supply services was a supply of property for HST/GST purposes

CRA found that a stipend paid by a hospital to a medical specialist for agreeing to stay close to the hospital so as to be available on an on-call basis was taxable consideration for the supply of property to the hospital rather than for a supply of an exempt medical service, stating:

[T]he hospital acquired a right to call upon the physician to attend the hospital during a given time period…[which] has a distinct utility to the hospital and as such…the right is a discrete supply that is separate from any health care services that may be rendered by the physician to patients of the hospital.

Neal Armstrong. Summary of 8 January 2016 Interpretation 150125 under ETA, Sch V, Part II, s. 5.