407 ETR – Tax Court of Canada finds that Ontario government charges to the 407 Highway operator for OPP patrol services were for an HST-exempt supply of a “municipal service”

D’Arcy J noted that since “policing services are one of the core services provided by a municipality,” and since the HST exemption in Sched. V, Pt. VI, s. 21 on its face contemplates that an exempt “municipal service” can be supplied by a non-municipal government, it followed that charges of the Ontario government to the private operator of the 407 Highway for OPP patrol services were exempted as a “municipal service,” as they “were of the same nature as services typically provided by municipalities.”

Neal Armstrong. Summary of 407 ETR Concession Co. Ltd. v. The Queen, 2016 TCC 213 under ETA Sched. V, Pt. VI, s. 21.