CRA finds that dental services provided to the patients of a dentist's professional corporation were GST exempt

ETA Sched. V, Pt. II, s. 5 exempts health care services “rendered” by a medical practitioner, such as a licensed dentist, to an individual. CRA ruled that this exempted the dental services provided by a dentist to patients notwithstanding that it was the corporation of which he was sole shareholder (and not an employee) which billed the patients for his services. It stated:

[R]egardless of whether the dental services are supplied through the Dentist’s clinic or directly by the Dentist, the exemption under section 5 would still apply.

CRA went on to find that the dividends received by him “as the only form of consideration for the work he performs for the Company” were exempted, i.e., CRA did not recharacterize the dividends as compensation for his services.

Neal Armstrong. Summaries of 4 November 2021 GST/HST Ruling 196473a under ETA Sched. V, Pt. II, s. 5 and s. 123(1) – financial service – (f).