CRA explains the ETA s. 213.2 rules for importing goods free of GST

CRA described ETA s. 213.2 as establishing an import certificate regime allowing registered importers to obtain a CRA certificate permitting them to import - free of GST/HST otherwise imposed at the border – goods owned by a non-resident person for the purpose of providing a storage or distribution service, or performing certain manufacturing or processing services, in respect of those goods prior to their export (with the provision also extending to the importation of goods or raw materials, other than fuels, lubricants and plant equipment, for consumption or absorption directly in the processing of other goods for export.)

CRA confirmed that a Canadian manufacturer could not obtain such a certificate respecting its importation of goods from a registered US supplier given that it was not necessarily receiving the goods for their export or for the purpose of providing a service in respect of them to the non-resident supplier. Thus, the importer was subject both to GST at the border (under Division III) and to the GST charges of the non-resident supplier (under Division II).

Neal Armstrong. Summary of 1 September 2020 GST/HST Interpretation 180336 under ETA s. 213.2(1).