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.
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Excise Duties and Taxes Division
Place de Ville, Tower A, 20th floor
320 Queen Street
Ottawa, ON K1A 0L5
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Case Number: 97242
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XXXXX
XXXXX
XXXXX
XXXXX
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January 16, 2008
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XXXXX
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Dear Sir:
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Subject:
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EXCISE TAX RULING
Part I Tax on Insurance Premiums (Other Than Marine)
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Thank you for your facsimile XXXXX concerning the application of the Excise Tax Act (ETA) with respect to Part I Tax on Insurance Premiums (Other Than Marine) to XXXXX. I apologize for the delay in responding to this matter.
All legislative references are to the ETA and the regulations therein, unless otherwise specified.
Statement of Facts
1. XXXXX, a Canadian corporation, is an insurance broker located in Canada.
2. XXXXX is selling Mexican insurance on their website to cover Canadian residents' vehicles and watercraft only while they are located in Mexico.
3. It is illegal to drive in Mexico without liability insurance issued by a Mexican Insurance company.
4. No insurers in Canada XXXXX are able to extend their liability coverage to Mexico.
Ruling Requested
You would like to know whether Part I Tax on Insurance Premiums will apply to Mexican Insurance being sold on your website to Canadian residents for coverage on their vehicles and watercraft while they are visiting Mexico.
Ruling Given
Based on the facts set out above, we rule that Part I Tax on Insurance Premiums will not apply to the Mexican insurance sold to Canadian residents for coverage on their vehicles and watercraft while in Mexico.
This ruling is subject to the qualifications in GST/HST Memorandum 1.4, Goods and Services Tax Rulings. We are bound by this ruling provided that none of the above issues is currently under audit, objection, or appeal, that no future change to the ETA, regulations or our interpretative policy affect its validity, and all relevant facts and transactions have been fully disclosed.
If you require clarification with respect to any of the issues discussed in this letter, please call me directly at (613) 954-4132.
Yours truly,
Joan Thompson
Rulings Officer
Excise Taxes and Other Levies
Excise Duties and Taxes Division
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