CRA indicates documentary flexibility re pipeline zero-rating requirements

In order for the "first seller" to zero-rate the supply of continuous transmission (pipeline) commodity (“CTC”) to the "first buyer" referenced in ETA Sch. VI, Pt. V, s. 15.1, the first buyer must have documentation satisfactory to CRA that the CTC has been supplied to a registrant and all or part of the consideration is property of the same class or kind delivered to the first buyer outside Canada. CRA stated that it will accept invoices or agreements which:

contain such information as would be required to determine the following:

  • The CTC exchanged is of the same class or kind purchased.
  • The place of delivery of the CTC to the registrant inside Canada.
  • The place of delivery of the exchanged CTC to the first buyer outside Canada.
  • Identity of the registrant including their BN.

Neal Armstrong. Summary of May 2016 Alberta CPA Roundtable, GST Q.1 under ETA Sch. VI, Pt. V, s. 15.1.