CRA indicates that fees paid by a land developer to a regional municipality to obtain approvals preliminary to receiving GST/HST-exempt permits from the local municipality are not also exempt

Sch V, Pt VI, s. 20(c) exempts the supply of a municipal permit and related processing services from GST/HST. Where a land developer is applying for a final building or service permit of the local municipality, it may first have to obtain the approval of the land development agreement by the regional municipality, for which it is charged separate fees. In rejecting a submission that such additional fees are part of the consideration for a single supply of the ultimate permits, CRA noted that “the provision of property and/or services by two or more suppliers generally indicates that multiple supplies are being made, even if the various supplies are provided together,” and that “many of the fees identified are payment for a separate supply, e.g., approval of a plan amendment or a condominium conversion.”

Neal Armstrong. Summaries of 27 May 2016 Interpretation 130865 under ETA Sch V, Pt VI, s. 20(c), Sch V, Pt VI, s. 21 and s. 189.1.