CRA notes issues on the GST/HST boundary line between qualified acupuncturist supplies and taxable supplies

The supply by a “practitioner” of acupuncture services was exempted effective February 12, 2014. One complication is that the profession is not provincially regulated in smaller provinces (Manitoba, Saskatchewan, Prince Edward Island, Nova Scotia and New Brunswick). CRA helpfully suggests that those with acupuncture practices in those provinces “contact the regulatory body in any of the regulated provinces to determine if their qualifications are equivalent to those necessary to be licensed or otherwise certified in that province,” so as to determine if they qualify as “practitioners.”

Mixed supply issues may also arise. CRA provides an impractical example of a dual-qualified professional who meticulously invoices for 40 minutes of acupuncture and 20 minutes of massage therapy, and states that it would assume that there were separate supplies of massage therapy (which is not exempted) and of acupuncture. A sale of herbal goods would also not be assimilated to the acupuncture supply (and would not be zero-rated as a grocery supply).

Neal Armstrong. Summaries of GST/HST Technical Information Bulletin B-110 “Application of the GST/HST to the Practice of Acupuncture” April 2017 under ETA, Schedule. V, Pt, II, s. 7, s. 1 – practitioner, Sched. VI. Pt. III, s. 1.