Predominant element of ABM supply by downstream merchant is real estate licence or other taxable supply
…Shared cash dispensing allows a person to obtain cash or a cash advance using a debit, credit or charge card from ABMs not owned by the person’s financial institution.
The term “downstream merchant” described in GI-006 deals with a merchant (that is not a card acceptor) that provides space or a location for an ABM owned by another person. …
In these circumstances, often the predominant element of the supply made by a downstream merchant is the provision of a licence in respect of real property (that is, providing space or a location for the ABM). This is a taxable supply. … Where the predominant element of the supply consists of replenishing money, providing telephone lines, electricity or any combination thereof, the supply would also generally constitute a taxable supply.