Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence.
XXXXX
XXXXX
XXXXX
Excise and GST/HST Rulings Directorate
Place de Ville, Tower A, 15th floor
320 Queen Street
Ottawa ON K1A 0L5
Case Number: 106433
Attention: XXXXX XXXXX
October 26, 2010
Dear XXXXX:
Subject:
GST/HST RULING
Camp programs and XXXXX
Thank you for your letter of XXXXX, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to camp programs and XXXXX.
HST applies at the rate of 15% in Nova Scotia, 13% in Ontario, New Brunswick, and Newfoundland and Labrador, and 12% in British Columbia. GST applies at the rate of 5% in the remaining provinces and territories.
All legislative references are to the Excise Tax Act (ETA) unless otherwise specified.
Statement of Facts
We understand
1. XXXXX.
2. XXXXX.
3. XXXXX.
4. XXXXX.
5. XXXXX.
6. XXXXX registered for GST/HST purposes. Under its business number XXXXX has a GST/HST program account XXXXX and a registered charity program account XXXXX.
7. XXXXX The facilities and amenities available at XXXXX include campsites, lodging, dining room, lounge, cafe, chapel, playground, walking trails, XXXXX, meeting rooms, high speed wireless Internet access, public access computer terminals XXXXX, XXXXX gift shop, sport shop, public washrooms and XXXXX.
Overnight family camp programs
8. Each summer, the Charity offers overnight family camp programs at XXXXX. Families or individuals can attend camp programs for one or more nights or for one or more weeks or for the season XXXXX. The overnight family camp programs are:
• XXXXX Family Camp program with campsite/trailer/chalet suite - This program includes a campsite or housekeeping trailer or the chalet suite with kitchenette, XXXXX programming, instruction and supervision in sporting and recreational activities and use of facilities. The price for the program includes a mandatory program fee for each adult and child XXXXX and the rental of the campsite or housekeeping trailer or chalet suite. Meals are optional. Individual meals can be purchased in the café or dining room or families can prepay for a package of XXXXX meals. Staff at XXXXX prepare the meals which are sold for more than their direct cost (that is, the meal prices are calculated at cost plus a mark-up XXXXX.
• XXXXX Family Camp program with accommodation and meals - This program includes motel or lodge style accommodation, meals, XXXXX programming, instruction and supervision in sporting and recreational activities and use of facilities. The price for the program includes a mandatory program fee, a mandatory meal contract, and the rental of the accommodation. XXXXX.
• Seasonal Camp program with campsite - This program for families and individuals includes a seasonal campsite XXXXX, XXXXX programming, instruction and supervision in sporting and recreational activities and use of facilities. The price for the program includes a mandatory program fee and the rental of the campsite. Meals are optional.
9. XXXXX Children and teens have structured programming of XXXXX hours a day (XXXXX instruction and supervision and instruction in sports, crafts, games and recreational activities). There are daily activities and sports for the whole family during the afternoons. The Charity does not provide overnight supervision as the children stay in accommodations with their parents. Adults have access to XXXXX programming XXXXX as well as structured recreational activities (e.g., tennis tournaments, trail/hike interpretations, etc.). Additionally, adults and children have access to unstructured use of sporting and recreational facilities on the grounds and can attend entertainment events (e.g., movies, dramas, concerts) XXXXX.
10. Recreational activities available at XXXXX include swimming at the beach or pool (supervised by lifeguards), using the XXXXX, taking a XXXXX boat cruise, canoeing, archery, wall climbing, high ropes climbing, kayaking, fishing, and playing a variety of sports such as baseball, basketball, volleyball, soccer, lawn bowling, shuffleboard, badminton, tennis or mini-putt. Golf is available from XXXXX through XXXXX on the XXXXX golf course for an extra fee. Teens and youth can learn XXXXX, wilderness survival, fine arts and drama.
Day camp programs
11. The Charity offers a "XXXXX Day Camp" program at XXXXX during the summer season for children and youth in two age groups (grades 1-3 and grades 4-6). Each day camp runs weekly from Monday to Friday and children cannot be registered for partial days. The registration fee for the weekly day camp program includes Bible teaching, instruction and supervision in sporting and recreational activities, daily lunch and a t-shirt.
12. The Charity also offers an optional overnight sleepover for both age groups on XXXXX night for an extra fee that includes a camp-out, campfire, wagon ride and entertainment. Group leaders employed by the Charity instruct and supervise the children in various sports and recreational activities and provide the overnight supervision. XXXXX. The overnight option cannot be purchased on its own; that is, it must be purchased along with a weekly day camp program.
13. Children in grades 1-3 attending the day camp participate in a morning of skits, songs, stories, games and crafts XXXXX. Afternoons include supervision and instruction in activities such as rock-climbing, canoeing, XXXXX boat rides, sandcastle competitions, water games, sports and other fun activities.
14. Children in grades 4-6 participate in the "XXXXX Program". In the morning children participate in Bible teaching and in XXXXX of the following skills: canoeing; wilderness survival; golf; drama; archery; swimming; high ropes/climbing; active sports; arts and crafts. Afternoon activities include supervision and instruction in outdoor games, team building challenges, field games, water activities and other recreational activities.
15. While the Charity does not specifically offer a day camp program primarily to individuals who have a disability, children with special needs attending its day camps are integrated into its regular camp programs and, if necessary, additional group leaders or special needs workers may be assigned to those groups.
Conference and XXXXX Centre packages
16. The Charity operates a year-round conference and XXXXX facility for XXXXX groups, families and individuals at XXXXX. It offers the following styles of XXXXX packages:
• XXXXX Centre - The Charity provides large and small groups of families or adults with a variety of accommodation styles ranging from hotel style rooms to lodge style buildings as well as a selection of meeting rooms and buffet-style meals in the dining room. The all-inclusive price per person for this XXXXX package includes accommodations, meals, meeting room, XXXXX fee XXXXX, and usage of recreational facilities and equipment (other than those facilities and equipment for which there is a separate charge).
XXXXX Youth Camp - This XXXXX is geared towards youth groups as well as other groups requiring a more economical alternative with simpler accommodations (bunk beds) and smaller meeting rooms. Buffet-style meals are provided in the dining room. The all-inclusive price per person for this XXXXX package includes accommodations, meals, meeting room, XXXXX fee, and usage of recreational facilities and equipment (other than those facilities and equipment for which there is a separate charge). XXXXX.
17. Depending upon the time of year, conference and XXXXX guests can engage in such recreational activities as canoeing, swimming at the beach or pool, fishing, hiking, shuffleboard, lawn bowling, table tennis, paddle boats, horseshoes, baseball, basketball, volleyball, soccer, broom ball, tennis, children's playground, pool tables, campfires, mini-putt, XXXXX and cross-country skiing. The use of the recreational facilities and equipment at XXXXX is self-directed for conference and XXXXX guests; however, for a separate fee, any guest can enrol in an activity where instruction is provided. There is also a separate charge to play XXXXX, to use a watercraft, or to take a cruise or a wagon ride.
18. Conference and XXXXX groups can also choose to acquire a XXXXX Package for an extra fee. XXXXX
19. The Charity's XXXXX coordinators can also assist in the design and implementation of a personalized conference or XXXXX package for any group.
XXXXX Centre
20. During the non-summer seasons, the Charity provides a large number of school groups with its XXXXX program at XXXXX. The majority of the school groups are from grades 5 to 8 but high-school groups also attend. The students come from XXXXX schools to learn about the environment, participate in outdoor recreational activities and to develop life skills.
21. School groups choose from a list of environmental and outdoor recreational programs to undertake during their visit XXXXX. Instruction in the programs is provided by the Charity's staff at XXXXX. For overnight stays, the students are supervised in their accommodations by teachers and volunteer parents accompanying the group.
22. XXXXX
23. The price for a XXXXX night XXXXX program at XXXXX includes the programming and instruction in activities, equipment and facility use, meals and accommodation. XXXXX day-use programs are available as well. These short-term programs have been created by the Charity's staff at XXXXX and do not follow a curriculum designated by a school authority. These programs also do not qualify for a school credit.
24. A Form GST26, Election or Revocation of an Election by a Public Service Body to Have an Exempt Supply of Real Property Treated as a Taxable Supply, has not been filed in respect of the property at XXXXX.
Ruling Requested
You would like to know the application of the GST/HST to the above-described camp programs and conference and XXXXX packages offered by the Charity at XXXXX. Specifically, you ask whether or not the GST/HST applies separately on the mandatory program fees, rentals of campsites or housekeeping trailers, rentals of accommodations, mandatory meal contracts, optional meals, day camp programs, conference and XXXXX packages and XXXXX programs.
As outlined in GST/HST Memoranda Series 1.4, Excise and GST/HST Rulings and Interpretations Service, a ruling provides the Canada Revenue Agency's (CRA's) position on how the relevant provisions of the legislation apply to a clearly defined fact situation of the taxpayer. Where sufficient information and documentation has been provided regarding a transaction, we have issued a ruling.
However, as the conference and XXXXX packages supplied by the Charity may be customized to meet the specific needs of a customer, we have provided an interpretation on how the GST/HST applies to these types of supplies when made by a charity in the explanation that follows the ruling given.
Ruling Given
Based on the facts set out above, we rule that
• the following supplies made by the Charity are taxable supplies subject to the GST/HST:
- XXXXX Family Camp program with campsite or trailer or chalet suite accommodation;
- XXXXX Family Camp program with accommodation and meals;
- Seasonal Camp program with campsite;
- XXXXX programs provided primarily to children in high-school grades 10 and over;
- Optional meals; and
• the following supplies made by the Charity are exempt supplies not subject to the GST/HST:
- XXXXX weekly Day camp program provided primarily to children in grades 1 to 6;
- XXXXX weekly Day camp program with one overnight stay provided primarily to children in grades 1 to 6; and
- XXXXX programs provided primarily to children in grades 5 to 8 with no overnight supervision provided by the Charity.
This ruling is subject to the qualifications in GST/HST Memorandum 1.4, Excise and GST/HST Rulings and Interpretations Service. We are bound by this ruling provided that none of the above issues are currently under audit, objection, or appeal, that no future changes to the ETA, regulations or our interpretative policy affect its validity, and all relevant facts and transactions have been fully disclosed.
Explanation
Single supply or multiple supplies
In determining whether a supply made by the Charity of a particular program or package to a customer is a taxable supply or an exempt supply for GST/HST purposes, it is first necessary to determine whether the program or package is a single supply or consists of multiple supplies. This is important in a transaction where a combination of elements is provided to the customer, some of which could be subject to the GST/HST, and some of which could be exempt from the GST/HST, if supplied separately. The principles outlined in GST/HST Policy Statement P-077R, Single and Multiple Supplies, can be used to determine whether a particular transaction consists of a single supply or multiple supplies.
In applying the principles outlined in GST/HST Policy Statement P-077R, one must consider such factors such as the interrelationships and interdependency among the various elements of the transaction as well as the purpose of the transaction. Each transaction for a camp program or a conference and XXXXX package must be reviewed on its own to determine whether it consists of a single supply or multiple supplies.
It should be noted that the way in which the price for a program or package is set out does not in itself determine whether there exists one or more supplies. Separately identified charges for certain elements do not necessarily mean that there are two or more supplies. The structure of the transaction is examined to determine if the provision of any particular element is contingent on the provision of one or more elements. If the recipient of the supply does not have the option to acquire the elements separately, then generally, there is a single supply.
Where a program or package offers optional supplies of property or services, the program or package may generally be considered to consist of multiple supplies. Where a program or package is composed of multiple supplies for a single consideration then it must be determined if one or more of the supplies may reasonably be regarded as incidental to the primary supply.
The incidental rule under section 138 provides that an incidental supply is treated as part of the primary supply and will have the same tax status as the primary supply. In general, a supply may reasonably be regarded as an incidental supply where it is of a minor, subordinate or non-essential nature to the overall supply or is nominal in value. However, section 138 does not apply if a separately identifiable charge is made for the incidental supply.
Overnight family camp programs
The purpose of the overnight family camp programs described above is to provide a camp experience for the whole family. Guests acquiring a overnight family camp program pay consideration to attend the camp and receive programming services, including supervision and instruction in recreational and athletic activities, the right to use the camp's facilities and a particular type of overnight accommodation. Also, for an overnight family camp program with motel or lodge style accommodation (other than the chalet suite), an non-optional meal contract is included. The program fees are a mandatory component of all the family camp programs. Campsites, trailers and other accommodations cannot be acquired on their own; they are provided as an integral part of a overnight family camp program. Overnight family camp programs must be purchased as a package.
Thus, after taking into consideration the principles in GST/HST Policy Statement P-077R, the following overnight family camp programs supplied by the Charity are single supplies for GST/HST purposes:
• XXXXX Family Camp program with campsite/trailer/chalet suite
• XXXXX Family Camp program with accommodation and meals
• Seasonal Camp program with campsite.
Customers acquiring an overnight family camp program that includes a campsite, trailer or the chalet suite have the option to acquire a meal package or individual meals at the cafe or dining room. These are separate supplies for separate consideration and are not part of the single supply of an overnight family camp program that includes a campsite or trailer or the chalet suite. Information on the tax status of optional meals is provided later in the letter.
The next step is to determine whether a particular supply of an overnight family camp program made by a charity is a taxable supply or an exempt supply. Exempt supplies are listed in Schedule V and are not subject to the GST/HST.
Most supplies of property or services made by a charity are exempt supplies under section 1 of Part V.1 of Schedule V unless the supply is excluded from exemption under paragraphs (a) to (n) of that section. However, there are other provisions under Schedule V that may apply to exempt certain supplies of property or services made by a charity.
In particular, paragraph 1(f) of Part V.1 of Schedule V excludes from exemption a supply of a service involving, or a membership or other right entitling a person to, supervision or instruction in any recreational or athletic activity. However, there are two exceptions to this exclusion and the supply will be exempt where:
(i) it could reasonably be expected, given the nature of the activity or the degree of relevant skill or ability required for participation in it, that such services, memberships or rights supplied by the charity would be provided primarily (more than 50%) to children 14 years of age or under and the services are not supplied as part of, the membership is not in, or the right is not in respect of, a program involving overnight supervision throughout a substantial portion of the program; or
(ii) such services, memberships or rights supplied by the charity are intended to be provided primarily to individuals who are underprivileged or who have a disability.
Please note that paragraph 1(f) of Part V.1 of Schedule V does not specify an extent to which the service or membership or other right must involve supervision or instruction in the recreational or athletic activity. Therefore, where a camp program involves any supervision or instruction in any recreational or athletic activity, the supply by a charity will not be exempt under section 1 of Part V.1 of Schedule V unless the camp program will be provided primarily to children aged 14 years old or under and does not involve overnight supervision throughout a substantial portion of the program or the camp program will be provided primarily to individuals who are underprivileged or who have a disability. Overnight supervision would include supervision by employees or volunteers of the charity.
The family camp programs offered by the Charity are intended for, and designed for, the whole family. Supervision and instruction is provided in structured recreational and athletic activities for the adults, the children, and the whole family. Thus, the exception listed under subparagraph 1(f)(i) of Part V.1 of Schedule V will not apply as the overnight family camp programs are not intended to be provided primarily to children 14 years of age or under but are intended for families of all ages.
Even where the overnight camp programs are acquired by adults who choose not to participate in the structured recreational and athletic activities, the overnight camp programs will still be excluded from exemption under paragraph 1(f) of Part V.1 of Schedule V as the camp programs include a service involving, or a right entitling a person to, supervision or instruction in recreational or athletic activities. It is the nature of the supply being made by the charity that is key in determining its tax status and not the extent to which the customer will utilize the service of, or exercise the right to, supervision or instruction in any recreational or athletic activity.
While individuals with disabilities are accommodated in the regular family camp programs described above, the programs are not intended to be provided primarily to individuals with disabilities. Also, based on the available information regarding these camp programs, they are not intended to be provided primarily to individuals who are underprivileged. Thus, the exception listed under subparagraph 1(f)(ii) of Part V.1 of Schedule V will not apply to the Charity's supplies of the family camp programs.
Therefore, as there are no other exempting provisions in Schedule V that may apply, supplies made by the Charity of the overnight family camp programs, as described above, will be taxable supplies subject to the GST/HST.
Day camp programs
A supply made by the Charity of a weekly XXXXX Day Camp program, as described above, with no overnight supervision, is an exempt supply under section 1 of Part V.1 of Schedule V where it is provided primarily to children 14 years of age and under.
However, where a customer enters into a transaction with the Charity for the provision of a weekly day camp program with a supervised overnight sleepover, then a single supply/multiple supplies analysis must be undertaken.
Where the overnight sleepover is optional and can be acquired on its own without the acquisition of the weekly day camp program then, generally, the overnight sleepover would be a separate supply and not part of the supply of the weekly day camp program. However, based on the information provided, the acquisition of the overnight sleepover is contingent upon the acquisition of a weekly day camp program. In other words, a customer cannot acquire the overnight sleepover on its own but must acquire it together with a weekly day camp program as a package.
Thus, where the Charity makes a supply of a XXXXX weekly day camp program that includes the one supervised overnight sleepover, this is a single supply that will be an exempt supply when provided primarily to children 14 years of age or under (e.g., children in grades 1 to 6). The provision of the one supervised overnight sleepover will not exclude the supply from being exempt as one night in a 5-day weekly day camp program is not considered to be a substantial portion of the program.
XXXXX Centre
School groups attending the XXXXX Centre for a XXXXX-day XXXXX program are acquiring a supply of a program of a service involving, or a right to, supervision and instruction in environmental activities and in recreational and athletic activities. Such a supply made by a Charity will be an exempt supply under section 1 of Part V.1 of Schedule V when provided primarily to students 14 years of age and under.
The exemption under section 1 of Part V.1 of Schedule V will also apply where the Charity makes a single supply of a XXXXX day program of instruction with overnight accommodation and meals as an all-inclusive program for a single consideration where it is provided primarily to students 14 years of age or under and the overnight supervision is provided by another party (e.g., teachers of the school or volunteer parents).
However, if the supply of a XXXXX day program is provided primarily to individuals over 14 years of age (e.g., students in high school grades 10, 11 and 12) or if the program involves overnight supervision by the staff or volunteers of the Charity throughout a substantial part of the program, then the supply of the program will be excluded from exemption under paragraph 1(f) of Part V.1 of Schedule V unless the program is provided primarily to individuals who are underprivileged or who have a disability.
Where the supply of an XXXXX program provided by the Charity at the XXXXX Centre is excluded from exemption under paragraph 1(f) of Part V.1 of Schedule V, it will be a taxable supply subject to the GST/HST as there is no other exempting provision in Schedule V that will apply.
Optional meals
Where the Charity provides optional meals for a separate consideration which is not contingent on the acquisition of a family camp program, day camp program, XXXXX program or conference or XXXXX package, the meals will generally be treated as a separate supply. A supply of a meal is a supply of tangible personal property.
Paragraph 1(d) of Part V.1 of Schedule V excludes from exemption a supply of tangible personal property that was acquired, manufactured or produced by the charity for the purpose of making a supply of the property and was neither donated to the charity nor used by another person before its acquisition by the charity, or any service supplied by the charity in respect of such property, other than such property or such a service supplied by the charity under a contract for catering.
Thus, where the Charity produces and prepares meals for supply in its café or dining room, the supplies will be excluded from exemption under paragraph 1(d) of Part V.1 of Schedule V as the meals are neither used nor donated to the Charity nor supplied by the Charity under a contract for catering. For information on what is considered a catering service, please refer to GST/HST Memoranda Series 4.3, Basic Groceries, beginning with paragraph 126.
The supplies of the meals will be subject to the GST/HST unless another exempting provision in Schedule V applies. However, the Charity's supplies of meals for more than direct cost provided in its café or dining room that it operates on a regular basis throughout the year will not be exempt supplies under any other provision in Schedule V and, therefore, will be taxable supplies subject to the GST/HST.
Interpretation Given
XXXXX Centre conference and XXXXX packages
As with the supplies of the family camp programs, each particular conference and XXXXX package must be reviewed on its own to determine whether the package consists of a single supply or multiple supplies. Then the tax status is determined for each supply.
Based on the information available, a XXXXX Centre package or a XXXXX Youth Camp XXXXX package includes, for an all-inclusive price per person, the following: a meeting room; accommodations; meals in the dining room; and self-directed use of recreational facilities and equipment (other than those facilities and equipment requiring a separate fee). Optional goods and services, such as rounds of golf and a XXXXX package with instruction and supervision in recreational activities, can be acquired for an additional fee per person.
Where a charity makes a supply of a conference and XXXXX package that includes a meeting room, accommodations, meals and self-directed use of recreational facilities and equipment and all these elements must be purchased together as an all-inclusive package for a single consideration, then generally it will be considered a single supply of real property by way of lease, licence or similar arrangement.
Supplies of real property by way of lease, licence or similar arrangement by a charity will be exempt supplies under section 1 of Part V.1 of Schedule V unless the charity has made an election under section 211 to treat supplies of the real property as taxable by filing Form GST26 in respect of the property. Also, the exemption under section 1 of Part V.1 of Schedule V applies to any goods (e.g., tables, chairs, audio-visual equipment, etc.) that are provided as part of the single supply of the real property by way of lease, licence or similar arrangement. However, any optional goods and services supplied for separately identifiable consideration will generally be separate supplies and the tax status is to be determined for each of those supplies.
Please note, that as a conference and XXXXX package can be tailored to the customer's needs, the nature of the supply of the package may not always be a supply of real property by way of lease, licence or similar arrangement. For instance, where the Charity provides a conference and XXXXX package where the dominant element is the provision of a service of XXXXX instruction by the Charity, then the supply will generally be that of a service rather than a supply of real property even where the use of a meeting room and accommodation may be provided in the package.
In addition, a personalized conference and XXXXX package may be in the nature of a camp program where supervision or instruction in any recreational or athletic activities is provided as well as XXXXX instruction. In this situation, the supply of such a package may be excluded from exemption under paragraph 1(f) of Part V.1 of Schedule V.
HST
In general, the HST at the rate of 13% (5% federal part and 8% provincial part) applies to taxable (other than zero-rated) supplies of property and services made in Ontario for which consideration becomes due, or is paid without having become due, on or after July 1, 2010.
Supplies of property and services made by charities that are exempt for GST purposes will also be exempt supplies for HST purposes. Supplies of property and services that are taxable for GST purposes will also be taxable for HST purposes. As a result, charities that are GST/HST registrants will generally have to collect the HST on all taxable (other than zero-rated) supplies of property and services that they provide to their customers effective July 1, 2010.
A charity is entitled to claim public service bodies' rebate of 50% of the GST or the federal part of the HST on eligible purchases. A charity resident in Ontario is entitled to claim a public service bodies' rebate of 82% of the provincial part of the HST on eligible purchases.
Please note that while the HST came into effect in Ontario on July 1, 2010, there are transitional rules that apply to transactions that straddle the July 1, 2010, implementation date for the HST.
Certain non-consumers, including charities, may be required to self-assess the provincial part of the HST when they purchase taxable property or services to be provided on or after July 1, 2010, and consideration for the property or services became due, or was paid without having become due, after October 14, 2009 and before May 2010. Also, suppliers in Ontario, including charities, are generally required to charge the HST on consideration that becomes due, or is paid without having become due, on or after May 1, 2010, and before July 2010, for taxable supplies of property or services to be provided after June 2010.
More information on the HST in Ontario is available in various publications available on the CRA Web site including the following:
• GST/HST Notice 253, Harmonized Sales Tax for Ontario and British Columbia - Questions and Answers for Public Service Bodies;
• GST/HST Notice 247, Harmonized Sales Tax for Ontario and British Columbia - Questions and Answers on General Transitional Rules for Personal Property and Services;
• GST/HST Info Sheet GI-060, Harmonized Sales Tax for Ontario - Point-of-Sale Rebate on Newspapers;
• GST/HST Info Sheet GI-063, Harmonized Sales Tax for Ontario and British Columbia - Point-of-Sale Rebate on Children's Goods;
• GST/HST Info Sheet GI-064, Harmonized Sales Tax for Ontario - Point-of-Sale Rebate on Prepared Food and Beverages;
• GST/HST Info Sheet GI-065, Harmonized Sales Tax for Ontario and British Columbia - Point-of-Sale Rebate on Books; and
• GST/HST Info Sheet GI-106, Ontario First Nations Point-of-Sale Relief - Reporting Requirements for GST/HST Registrant Suppliers.
For more information on the tax status of various supplies made by charities, please refer to the GST/HST guide RC4082, GST/HST Information for Charities.
Other Information
Branches or divisions that are part of one legal entity (e.g., a corporation) cannot register separately for GST/HST purposes. If a corporation has to register, or registers voluntarily, it has to do so as a single entity. When the corporation registers with the CRA, it is issued a 9-digit business number (BN) that identifies the corporation. The BN is unique to that corporation and will always be the first nine digits of any account number that it has with the CRA (e.g., Registered Charity Account Number 123456789 RR0001, GST/HST Account Number 123456789 RT0001, Payroll Account Number 123456789 RP0001, etc.).
A corporation with branches or divisions can apply to have its branches or divisions file separate GST/HST returns and public service body rebate applications. Each branch or division has to be identifiable by either its location or the nature of its activities, and must keep separate books and records. Also, a corporation that is a charity may apply to have each branch or division with $50,000 or less in taxable supplies designated as a small supplier division. Information on these applications is available in GST/HST Memoranda Series 2.4, Branches and Divisions.
XXXXX.
XXXXX.
The foregoing comments represent our general views with respect to the subject matter of your request. These comments are not rulings and, in accordance with the guidelines set out in GST/HST Memorandum 1.4, Excise and GST/HST Rulings and Interpretations Service, do not bind the Canada Revenue Agency with respect to a particular situation. Future changes to the ETA, regulations, or our interpretative policy could affect this interpretation.
If you require clarification with respect to any of the issues discussed in this letter, please call me directly at 613-952-9592. Should you have additional questions on the interpretation and application of GST/HST, please contact a GST/HST Rulings officer at 1-800-959-8287.
Yours truly,
Nadine Kennedy
Charities, Non-profit Organizations and Educational Services Unit
Public Service Bodies and Governments Division
Excise and GST/HST Rulings Directorate
XXXXX
XXXXX
XXXXX
XXXXX
XXXXX
UNCLASSIFIED
Email this Content