The Corporation provides medical repatriation services which involve arranging to transport an individual (the patient) from a foreign hospital to a health care facility in the individual’s home country. This would include transport between the medical facilities and airports via ground transportation (ambulance, taxi, or limo), and commercial airline transportation in the company of a medical escort (registered nurses, physicians and advanced cardiac life support trained paramedics). The Corporation charges a daily rate for the medical escort and a fee for the medical equipment required by the patient.
CRA found that the repatriation services were a single supply, stating:
The dominant element of the supply made by the Corporation is the medical escort services. The […][recipients] come to the Corporation because their patients require a medical escort to be able to travel and their needs would not be satisfied without these services. The logistical services are inputs that are consumed in the provision of the medical escort services.
CRA found that such supply did not qualify as a zero-rated “ambulance” service. However, it could qualify as an exempt nursing supply under Sched. V, Pt, II, s. 6 or an exempt physician supply under Sched. V, Pt, II, s. 5, depending on who accompanied the patient – whereas if the attendants were paramedics it would not be exempted.