19 September 1994 GST/HST Interpretation 11640-4(glr)[1] - Application of the GST to Certain Supplies Which were Exported

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Attached is a copy of a letter dated January 10, 1994 (File: XXXXX), written by Mr. XXXXX, XXXXX XXXXX Excise/GST Office, to the above-referenced registrant. The letter concerns the application of the GST to certain supplies which were exported.

XXXXX states that XXXXX does film work for production ready printing. In one particular case, XXXXX customer requested that the film work be exported. XXXXX contracted a courier company to export the film work. XXXXX charged its customer one amount for the supply, which included both the cost of the film work and the courier charges. XXXXX determined that XXXXX made a single supply of a service (the transportation service was incidental to the supply of the film work) and that the service is subject to the GST at 7%.

On September 12, 1994, Mr. Garry Ryhorchuk of my staff discussed this letter with Mr. XXXXX Interpretation and Service, XXXXX Excise/GST Office. The information on file indicates that XXXXX had a contract with a resident to produce imaged articles (i.e., colour separations). On instructions of the resident, the imaged articles were exported to another firm in XXXXX. It would, therefore, appear that XXXXX made a supply of tangible personal property to the resident, and not the supply of a service.

Provided XXXXX has evidence that the imaged articles were exported, the supply by XXXXX to the resident would qualify for zero-rating under the provisions of Schedule VI, Part V, section 1 to the Excise Tax Act.

If you require any further information, please contact Mr. Ryhorchuk at (613) 952-6743.

H.L. Jones
Director
General Tax Policy
Excise/GST
Policy and Legislation

Att.