Telephone: (613) 954-9585
Fax: (613) 990-1233
XXXXX File: 11640-1(mf)
XXXXX Sch. VI/V/18
XXXXX
I refer to your telephone conversation with Rob Allwright of my staff on January 31, 1994 and the related telefax transmission of February 1, 1994 concerning an audit of XXXXX[.]
The question discussed with Mr. Allwright relates to the application of section 18 of Part V of Schedule VI to the Excise Tax Act (Act). Specifically, does the certificate issued to non-resident persons by XXXXX meet the requirements of the provision?
Section 18 of Part V of Schedule VI to the Act zero-rates supplies of instructing non-resident individuals in courses leading to certificates, diplomas, licences or similar documents that attest to the competence of the individuals to practise or perform a trade or vocation. However, the form and content of these documents are not specified for purposes of Part IX of the Act.
The certificate issued by XXXXX verifies that the individual to whom the service was rendered has successfully completed a particular course. This format is fully acceptable for the purposes of section 18 of Part V of Schedule VI to the Act. If you require further information regarding this matter, please do not hesitate to contact Ms. Maxine Farrell at (613) 952-9204.
H.L. Jones
Director
General Tax Policy
Policy and Legislation
GTP: XXXXX
c.c.: R. Allwright
M. Farrell
S. Johnson, A/Director, Excise/GST Audit
L. Mohr, Department of Finance
XXXXX
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