Repsol – Federal Court of Appeal applies the “integration principle” to find that a jetty was a “processing” asset
Woods JA found that the LNG terminal in St. John qualified as a Class 43 property because it was engaged in "processing" (i.e., a conversion of LNG into gas form, viewed as representing a change in the goods that rendered them more marketable) and because the terminal was not a "distribution" asset (i.e., “distribution” did not commence until at least the delivery of the (converted) gas to the transmission pipeline.)
In finding that the jetty at which the tankers discharged the LNG was part of the terminal asset rather than a separate (Class 3) “jetty” asset, she applied “the judge-made integration principle … that processing includes all activities that are necessary and integral to the processing operation.” This perhaps is similar in effect to the single supply doctrine applied in the GST cases.
Neal Armstrong. Summary of Canada v. Repsol Energy Canada Ltd., 2017 FCA 193 under Sched. II, Class 1(n).