CRA may bifurcate what otherwise might be a single supply of flight training time into a GST/HST taxable and exempt component

CRA indicates that the supply of solo and dual flight time by a flight school to would-be pilots can qualify as exempt vocational training only to the extent that such flight time does not exceed the minimum times set by federal regulation for the provision of licences and ratings – and that the purchase of hours in excess of this minimum is taxable.

This is an unusual example of CRA purporting to bifurcate what otherwise might be a single supply of a service into two components. Such bifurcation arguably could be justified by Intrawest.

Neal Armstrong. Summaries of GST/HST Memorandum 20-4 “Vocational Schools and Courses” December 2019 under ETA Sched. V, Pt. III, s. 1 – vocational school, s. 6 and s. 8.