Telephone No.: (613) 954-8585
Fax No.: (613) 990-3602
File No.: 11640-3(cav)
Sch. VI/V/7
Re: GST Application Ruling - 'Plating Error Charge'
Dear Ms. XXXXX
I refer to your facsimile messages dated February 12, 1996 to Mr. Adrien Venne, Director, Special Sectors Division and February 13, 1996 to Mr. Adam Belyea of his staff, requesting a GST ruling concerning the tax status of XXXXX 'plating error charges' to resident and non-resident travel agents.
Statement of Facts
1. An unregistered non-resident travel agent issues a ticket to a passenger and plates the ticket to XXXXX[.]
2. If XXXXX is not carrying the passenger, XXXXX will charge the travel agent XXXXX for the plating error.
3. XXXXX[.]
Ruling Requested
The processing of plating errors, in Canada, where provided to a resident travel agent, is taxable at 7 per cent and zero-rated where provided to a non-resident travel agent.
Ruling Given
Based on the facts and the transactions set out above, we rule that the supply of the service of processing plating errors supplied by XXXXX to a resident travel agent is taxable at 7 per cent and to a non-resident travel agent is zero-rated under section 7 of Part V of Schedule VI to the Excise Tax Act (Act).
This ruling is subject to the general limitations and qualifications outlined in the GST Memoranda Series Section 1.4. We are bound by this ruling provided that none of the above issues are presently under audit, objection or appeal, there are no relevant changes in the future to the Act, and provided that you have fully described all necessary facts and transactions for which you requested a ruling.
Rationale
The processing of plating error charges is a service provided in Canada and is therefore taxable at the rate of 7 per cent to a resident travel agent. The same service provided to a non-resident travel agent is zero-rated under section 7 as the service is not considered to be primarily for the non-resident's use in Canada.
If you have any questions or require further information, please contact Carol Ann Villeneuve at (613) 957-8224 or Randy Nanner at (613) 952-8810.
Yours sincerely,
H.L. Jones
Director
General Applications Division
GST Rulings and Interpretations
Policy and Legislation Branch
Email this Content