Doc: 1173
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Subject:
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Ferry Services by XXXXX
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I refer to the memorandum from XXXXX dated March 8, 1995, and an earlier one from XXXXX dated January 19, 1995, to a member of my staff, namely, Tom Alley, concerning several questions related to the tax status of ferry services for the purposes of the Goods and Services Tax (GST). I apologize for the delay in responding.
There are several policy issues involved in this letter that have not yet been approved by the Policy Review Committee. However, the policies enunciated in this letter will have effect until changed or confirmed by that committee.
Firstly, I list the facts given in the incoming letter to you. Secondly, I list the four questions you asked followed by the seven questions posed by XXXXX Thirdly, I make some general comments on ferries. Next, I provide responses to the eleven questions., however, the questions are rearranged and grouped by issue. Lastly, comments are made on the draft interpretation letter.
Facts
Below is a listing of the relevant facts of the particular case as described in the letter from XXXXX dated August 11, 1994, and in a telephone conversation on February 14, 1995, between XXXXX[.] These facts are the basis on which several interpretations are requested.
1. XXXXX (hereinafter referred to as XXXXX) plans to offer a ferrying service over particular routes.
2. The ferry follows a fixed schedule between different stops. The return trip XXXXX[.] Passengers are free to disembark at stops that interest them and embark when it is convenient for them, subject to the schedule. A stop of three hours is planned for Port B on the attached Appendix.
3. According to the information available and the financial projections, the service of ferrying passengers and their vehicles will represent the majority of revenues and will exceed the sales from the bar and restaurant on board. Freight transportation services are also expected to be offered on the same route.
4. The permit requested for the ferrying service will be for the following classes:
1A passenger transportation;
2 freight transportation; and,
4 charter.
5. XXXXX does not organize any excursions at different stops and does not offer any organized or directed activities. Notwithstanding that, ferry personnel make presentations such as providing information on whales to make the voyage more enjoyable. XXXXX is also contemplating initiating negotiations with organizers of tour packages or organizing specific activities such as packaged fishing tours.
6. At each stop the passengers and their vehicles may get on or off the ferry. The fare is based on one way travel according to the destination of the passengers. Passage is not limited to one way travel; return tickets may be purchased.
7. As indicated in Appendix I, XXXXX[.] The passengers may take their vehicle and spend the day at Port B. The passengers may make their own reservations for staying on Island C and continuing on aboard the next onward ferry or retracing their path by the next ferry. XXXXX excursions will be publicized as a mini-cruise and will be operated on a fixed schedule.
Opinions Requested
1. What is the interpretation of "principal purpose"? The Excise Tax Act [hereinafter referred to as the ETA] does not define "principal purpose" and the term is found in three places in the ETA or in its schedules [all schedules named in this letter refer to schedules to the ETA unless otherwise stated]: subsection 123(1) definition of convention[;] Part VIII of Schedule V (ferry); and Part VII of Schedule VI (ferry).
However, the term "principal business" is used in subsection 149(1) of the ETA. In reference to a financial institution the term "principal business" is used in its common or ordinary meaning and refers to the person's chief or main business activities. Several criteria are used to determine which of a person's business is the principal business. There are three criteria that could apply to our case and they are as follows:
1) the profits realized by each segment of a person's business;
2) the volume and the value of the gross sales or transactions of each business; and the time, attention and efforts expended by the employees, managers or corporate officers in each business.
Is the use of the above criteria an acceptable method to determine a ferry's principal purpose? The client suggested another method based on space occupied by the vehicles versus cargo; would this be an acceptable method?
2. What is the interpretation of "between parts of a road or highway system that are separated by a stretch of water"?
If the transportation service is along the same river bank or if the wharf of embarkation and disembarkation are situated on private property would the transportation qualify as a service of ferrying "between parts of a road ... water"? Furthermore, if all destinations except the ultimate destination are served by a road or highway system, would the total trip be exempt or would it depend on the destination?
3. Should we consider all the services offered together to determine their tax status? For example, should XXXXX cruises, transport of goods, fishing excursions be considered together or should we look at each supply separately?
4. If XXXXX advertises their XXXXX excursions as a "mini-cruise" will this have an influence on the decision [about whether a separate supply is being offered]? If a stop-over of XXXXX hours is scheduled at Port B to permit passengers and their vehicles to visit the island would this be a factor to consider?
5. What does the expression "service of ferrying" include?
6. What is the significance of the expression "principal purpose"? Do we apply the usual definition of "principal" to mean 50% or more or apply another rule? In order to evaluate the principal purpose does one have to use the revenues from the transportation of motor vehicles and passengers against the total revenues? Could it be determined by the amount of space allocated for transporting motor vehicles and passengers relative to the total surface area, taking into consideration that the boat could also be used to transport merchandise?
7. Does the nature of the transportation permit received through government authorities to operate the boat provide a conclusive factor in determining the tax status for GST?
8. What is meant by the expression "between parts of a road or highway system that are separated by a stretch of water"? Could we consider that when the ultimate destination of the boat is not serving any road or highway system, that the service no longer qualifies as exempt, and is therefore taxable?
9. If the wharf of embarkation and disembarkation are situated on private property, would the boat transportation still be considered between a road or highway system separated by a stretch of water?
10. The ETA seems to suggest that a stretch of water has to be crossed in order for the transportation services to be considered a "ferry". If the transportation service is along the same river bank without crossing it, would it still qualify as a service of ferrying between parts of a road or highway system that are separated by a stretch of water?
11. When a service of transporting goods is added to the service of transporting motor vehicles and passengers, which method used would be appropriate to determine if the principal service constitutes a service of transporting motor vehicles and passengers?
Opinions Given
General Comments
Section 1 of Part VIII of Schedule V lists as an exempt supply:
A supply, other than a zero-rated supply, of a service of ferrying by watercraft passengers or property where the principal purpose of the ferrying is to transport motor vehicles and passengers between parts of a road or highway system that are separated by a stretch of water.
The section has two conceptual parts to it. The first concept is that individual supplies ("a supply") of a service of ferrying by watercraft passengers or property are exempt. For this concept, think of the fare for a passenger. The second concept is that certain criteria are imposed on the regular operations of the ferrying before those individual supplies can be exempt. For the second concept it may help to think of the operations of the ferrying on a larger scale. If the criteria on the larger scale are not met then the individual supplies will be taxable.
Answers to Specific Questions by Group
Service of Ferrying
Questions 3 and 4 deal with what is included in a service of ferrying.
Firstly, the phrase "service of ferrying" is not defined in the ETA so its ordinary meaning in the context should be used. Start with ordinary usage without context and then, after examining the words on their own, bring in the context in which the words were used.
Some common understandings about ferrying are that it usually refers to the transport of passengers (with or without freight). Ferries often carry passengers and motor vehicles because they serve as a way of linking roads. It is this type of ferrying service that the exemption is designed to cover. Although it is not necessary to qualify for exemption, many ferries have "roll-on roll-off" capabilities for vehicles in the vessel structures with associated docking and ramp facilities on land.
The French term in the legislation is "service de navette par bateau" which can be translated as "shuttle service" which gives a connotation of regularity of service on a set route. The transport of freight is normally referred to as shipping rather than ferrying. Ferrying also has a connotation of shorter distances. They often serve as a substitute for bridges or as a shorter way than a circuitous land route. Nevertheless, there are many ferries that cross seas or oceans.
Secondly, look at dictionary definitions. Nine definitions from six dictionaries are provided in Appendix II. Common ideas about the meaning of the noun or verb "ferry" are that:
(i) there is a boat carrying people or things over water;
(ii) passengers, vehicles and freight may be carried; and,
(iii) there is some regularity of service.
Thirdly, although not conclusive, it may help to look at definitions in other pieces of legislation including legislation governing the industry (e.g., the Hull Construction Regulations of the Canada Shipping Act has a definition of "ferry vessel" that uses the ideas of short runs, regularity, comparability to a bridge or tunnel and traveling over water).
Next, look at the context when trying to interpret section 1 of Part VIII of Schedule V. When interpreting phrase by phrase it may help, at first, to use the expression "service of ferrying by watercraft" rather than just "service of ferrying". Ferrying is sometimes used in the sense of ferrying an aircraft to a destination, often in the context of delivering an aircraft to a purchaser or delivering a repaired aircraft to its owner. For the purposes of the exemption the only concern is with ferrying by watercraft rather than ferrying by other means such as aircraft. Once the subset of ferrying that is done by watercraft is recognized then look back to the phrase "service of ferrying".
Finally, the Department has developed the view that a service of ferrying refers to watercraft transportation services provided on a particular route. Such a view is a logical and reasonable interpretation and results in the most competitively neutral treatment.
Therefore, the term "service of ferrying" does not refer to one particular type of service (e.g., XXXXX cruises, transporting goods or fishing excursions). All the services on a particular route must be looked at together.
As well, a service of ferrying does not refer to a single ticket as noted in the general comments above. If the term "service of ferrying" referred to the supply to a single person then either the principal purpose requirement would be redundant or the status of each ticket would depend on the circumstances of the purchaser. Neither of these results follows from the context of section 1 of Part VIII of Schedule V.
If the term "service of ferrying" referred to all the supplies of ferrying by a person (i.e., the ferry company and all its routes) then the tax status of the same service offered by two different persons on the same route could be different. The different status would result from different principal purposes of the total of all a person's supplies of ferrying including all other routes. Consider an example of one person who operates one ferry whose principal purpose is transporting only passengers. The supplies of such a service of ferrying are taxable. A second person providing the same service could have its ferrying service exempted if it had enough other routes with a principal purpose of transporting passengers and motor vehicles so that the principal purpose of all the person's ferrying services is shifted to allow all of the services to qualify for exemption. Consequently, this interpretation is rejected.
Another basis for a service of ferrying, which was found unacceptable for the same reason just mentioned, is to view a service of ferrying as referring to the operations of a business unit.
Destinations
Question 5 and 8 focus on what is considered to be a destination. The only requirement on the nature of a destination is that it be part of a road or highway system that is separated by a a stretch or water from another part of a road or highway system. Therefore, a service of ferrying may have multiple destinations or stops. Because we view a service of ferrying to refer to a particular ferry route, it follows that if there are several destinations they must be on the same trip or route. Once there are different trips to different destinations you have different routes and the service on each route would be a separate service of ferrying.
For example, if a person operates services of ferrying from a central departure point to three different destinations each route would qualify as a service of ferrying regardless of whether only one vessel is used or three different vessels are used. A different interpretation would lead to competitive inequities.
Consider also the case where a route has several stops where passengers and motor vehicles can embark or disembark but where the last stop (i.e., where the ferry begins to retrace its path or the stop farthest from the starting point) is only for passengers and has no roads. Such a routing may still qualify as an exempt service provided the principal purpose test is met. As will be seen below in the discussion of the principal purpose test, there is enough flexibility in the phrase "principal purpose" that having one stop that cannot serve motor vehicles will not preclude the categorization of such a service of ferrying from meeting the principal purpose test.
Three of the six dictionary definitions of ferry in Appendix II refer to regularity of service as being characteristic of ferries. However, there is no requirement that the service of ferrying be a service that is provided on a regular basis or following a specific schedule. For example, a ferry that only operates in a remote location may have no schedule and may depart only when enough traffic accumulates to make it economical to provide the service (e.g., 40% of capacity). Furthermore, many ferry routes in Canada are operated on a seasonal basis. Regular operation, specific scheduling and year-round operation may make it easier to evaluate what the principal purpose of the ferry is but they are not a requirement for providing a service of ferrying.
Principal Purpose
Questions 1, 6 and 11 all deal with how to interpret the phrase "principal purpose". The significance of the expression "principal purpose" is that it provides a test in determining whether a service of ferrying by watercraft is an exempt supply. The word principal can be interpreted to mean 50% or more. However, the term is not specific on the measure to be used and all the facts must be taken into consideration.
Going back to the earlier example of a route where the last outbound stop has no road and cannot load or unload motor vehicles, if all the other stops serve motor vehicles and passengers then it is fair to say that "the principal purpose of the ferrying is to transport motor vehicles and passengers between parts of a road or highway system". It is not sufficient to look only at the number of stops that cannot serve the loading or unloading of motor vehicles relative to the total number of stops. The volume of traffic at the various stops and the proximity of stops that serve only passengers to stops that serve both passengers and motor vehicles must also be considered when determining the principal purpose of the service.
The particular method used to determine the principal purpose must be fair and reasonable in the circumstances and the method must be used on a consistent basis from year to year. Those requirements apply whether using revenues or space or some other method of measurement as the basis for establishing the principal purpose.
There are circumstances where a particular method or formula for space may not be reasonable. For example, you have suggested space available to motor vehicles and passengers relative to the total space. If the term "total space" were to include space that was used for engines, the bridge and washrooms, and the amount of that space was significant, then the "total space" used in the formula would not reflect the total space available for transporting motor vehicles, passengers and freight and the method could be considered an unreasonable method.
A registrant should evaluate the ratio of the supplies of services of ferrying on a regular basis to see if the principal purpose criteria is met. The method or formula for evaluation must be used consistently from period to period. It is expected that for most registrants the period used will be a year but the timing of the evaluation is not set and any reasonable basis (such as a seasonal basis) would be accepted.
If a registrant is planning a new route then the financial and operational projections could be used to calculate what the principal purpose is. In that case, the same method used for evaluation on the financial and operational projections should be used once the actual results are achieved.
It is recognized that many ferries will transport freight without an accompanying passenger or vehicle. One proposal was to view the transporting of freight on a ferry as a freight transportation service which is a different kind of supply from a ferrying service. Such a view reflects the idea that ferrying has a narrower industry or legal meaning than in the former view. The freight transportation service would be carved out of, and evaluated separately from, other ferrying services in determining the principal purpose of the ferrying service. Once the evaluation of the non-freight transportation service ferrying meets the principal purpose criteria then all of the individual supplies of ferrying service are exempt. The ferrying of freight would have its own tax status according to the rules for freight transportation service.
The policy the Department has adopted follows a different view. The proper sequence of interpretation is to first see if the supply fits one of the descriptions of exempt supplies listed in Schedule V. If no description listed in Schedule V covers the supply then it is a taxable supply. Then look for a description of a zero-rated supply in Schedule VI that fits the supply in question and if there is a fit then the supply is zero-rated. In other words, Schedule V takes precedence over Schedule VI.
Section 1 of Part VIII of Schedule V describes a service of ferrying and does not exclude the service of ferrying freight provided the principal purpose test is met. Consequently, all of the ferrying services, including freight, must be evaluated together to establish what the principal purpose of the ferrying is.
This interpretation also is consistent with section 14 of Part VII of Schedule VI which zero-rates international ferrying services of the same type that are exempted under section 1 of Part VIII of Schedule V (i.e., services that meet the same principal purpose test). If the principal purpose test is not met then the ferrying services are taxable. However, the international passenger transportation will be zero-rated if it fits under section 2 or section 3 of Part VII of Schedule VI (e.g., not a day trip which is clearly intended to be taxed) and the international freight transportation service may be zero-rated under sections 6 through 10 of that Part. This policy respects the proper sequence of interpretation and leaves no gaps in zero-rating.
As stated earlier the method must be used on a consistent basis. The method to determine whether the principal purpose test is met would not be affected by the addition of the provision of a supply of a service of transporting goods.
Marine Permits
Question 7 concerns the nature of the transportation permit received through government authorities and whether it is a factor in determining the tax status for GST.
The nature of the transportation permit received through government authorities to operate a boat is not a conclusive factor in determining the tax status for GST. There is no reference in section 1 of Part VIII of Schedule V to permits, licences or certificates.
Certificates may be issued under the Canada Shipping Act using the Hull Construction Regulations or the Life Saving Equipment Regulations. Such certificates may be used as evidence of the limits of what a boat is permitted to carry. For example, if the permit either did not allow for carrying passengers or did not allow for carrying motor vehicles, then the ferry service would not be able to meet the principal purpose test of transporting motor vehicles and passengers.
Link in Road Systems
Questions 2, 8 and 9 deal with the meaning of the phrase "between parts of a road or highway system that are separated by a stretch of water".
There is no reference in section 1 of Part VIII of Schedule V to whether the land on which parts of a road or highway system are situated need to be private or public. If the wharf is privately owned and separates the water from a part of the road or highway system, it should not make any difference to the tax status of the service of ferrying by watercraft as long as the wharf is part of the road or highway system or part of the ferrying service. The ferrying service must connect to the road system in some way. Of course, all the other conditions in section 1 of Part VIII of Schedule V must be met.
On the issue of the last destination serving only passengers and not motor vehicles, see the earlier comments under destinations. Consider two extremes of this situation to show how the specific circumstances can affect the status.
At one extreme, the last destination, serving only passengers, is at the end of a long route but only a short ride away from the previous stop which served passengers and motor vehicles. In this case, it is reasonable to say the ferry service qualifies as exempt.
At the other extreme, the last distant destination may be the main reason for the existence of the ferry service, the wharves suitable for the loading and unloading of motor vehicles are at the beginning of the route and at a stop that is very close to the beginning. The ferry may be capable of carrying small motor vehicles between the beginning of the route and at the first stop at the expense of having fewer passengers fitting on to the ferryboat. In this case, the principal purpose of the ferrying service is to transport passengers and not to transport passengers and motor vehicles.
A Stretch of Water
Question 10 focuses on whether "a stretch of water" must be crossed. A ferry service along the same river bank without crossing the river would still qualify as a service of ferrying between parts of a road or highway system that are separated by a stretch of water (i.e., the answer to Question 10 is "yes"). Section 1 of Part VIII of Schedule V refers to road or highway systems separated by a stretch of water. A stretch of water is not a very restrictive phrase and should be interpreted in a broad manner. Consider some examples.
Take an example of a road that follows a river valley that, for several kilometres, has sides that are too steep for a road. For that distance, traffic passes between the two parts of the road system by the use of a ferry service by watercraft. Presuming the ferrying service met the principal purpose test, the individual supplies of a ferrying service would be exempt.
Also, consider the same river but with a road that connects the same points that the ferry does. The service of ferrying still meets the criteria of connecting parts of a road or highway system separated by a stretch of water. Section 1 of Part VIII of Schedule V does not require that there be no alternative land or air route.
Lastly, consider the case of a ferrying service that crosses a lake. The opposite shore is also the same shore as the one the ferry started at but that does not preclude it from qualifying as a service of ferrying.
The description of what qualifies as an exempt service of ferrying does not make any requirement that:
(i) there be a minimum distance to the stretch of water;
(ii) the stretch of water be from mainland to mainland (i.e., stretches of water between two islands or between mainland and an island will qualify);
(iii) the stretch of water be between opposite shores;
(iv) the stretch of water be over a river, a lake or a sea; or,
(v) the water be fresh water, salt water or a shallow marsh.
Comments on Your Draft Interpretation Letter
I have responded above to the questions you have asked. Below I make comments on the draft interpretation letter you submitted.
Response to Question 1
You have accurately described the term "navette" in your response to the first question in the draft. As you can see from the discussion above, thinking of the larger phrase "service of ferrying" or "service de navette" shifts the focus from the "ferry" or "navette" to the service being provided. Furthermore, I agree that time between stops and the number of stops are not factors in determining if a ferry service qualifies as exempt.
Response to Question 2
You have written that the method for evaluating the principal purpose must be fair and reasonable and "révisées sur une base annuelle". I agree with the "fair and reasonable" requirement and would add that the method must be used on a consistent basis from year to year. When the annual review is done, it should not be done with the objective of changing the method but to see if the service of ferrying still meets the same principal purpose test for qualification as an exempt supply given the results of the year.
For example, if the method gives a result of 60% of the supplies meeting the principal purpose test one year and the following year, because of the changing mix of services provided, gives a result of 40% of the supplies meeting the principal purpose test, then the supplies of the service of ferrying will become taxable supplies for the next year. The Department must take into account that such a change could represent a change in purpose or a change in demand affecting a route that has the same purpose. Therefore, great care must be used in evaluating these changes.
In your draft you have listed three acceptable bases for a method to determine the principal purpose of a service of ferrying:
1) the profits realized by each segment of the business;
2) the volume of transactions and the value of the gross sales of each business; or
3) the time, attention and efforts expended by employees, managers or corporate officers in each business.
These three are generally aimed at profits, outputs and inputs, respectively.
In my opinion, profit is not a very good indicator of the principal purpose because it depends on a mix of several factors: inputs, demand, efficiency and profit margins for different services. Variations in efficiency between two identical and competing services of ferrying should not result in a different tax status. Different profit margins for different services may result in a bias to or away from different services (e.g., freight versus passenger) when evaluating the principal purpose. Since profit measures are derived from such a mix of factors that do not deal directly with the purpose of the business, I would discourage use of a profit-based method.
Revenue-based methods have their own problems: the timing of recognition of revenue and the source of revenue can be manipulated to give a more favourable result for the principal purpose. Nevertheless, revenue based methods may be used and may be a good last resort.
As you indicated, a method based on inputs may be appropriate for determining the principal purpose. Because of the problems with the other two approaches you have mentioned, I would recommend that, where feasible, an input based approach be treated as preferable to the other two.
Other approaches are also possible and the Department must be open to approaches that were previously unidentified. You have written in your draft letter that space on a vessel reserved for vehicles and passengers is not an acceptable method for evaluating the principal purpose. Any approach may not be fair and reasonable if carried out in a biased manner but I think the space on a vessel may be used in this context if done with care. The design of the vessel used on a particular route may be a very strong indicator of the purpose of the service of ferrying and, in some cases, could be determinative.
For example, consider a coastal freighter that can carry passengers and can carry two motor vehicles by lifting them by crane and setting them crosswise on the deck. The passengers mix with the crew in a common mess. In this case, there is no space reserved specifically for motor vehicles or passengers and that fact is a strong indicator that the principal purpose of the service is freight transportation even though some ferrying of motor vehicles and passengers is done.
Response to Question 3
I agree with your comments.
Response to Question 4
In the last paragraph of your response to Question 4, you make two statements that I think I should comment on. First, you have written that, if the ultimate destination is not serviced by a road system, then the service of ferrying will be a taxable supply. However, the case described in the third paragraph in the section above with the heading "Destination" and the comments in the last three paragraphs in the section above with the heading "Link in Road System" show that a service of ferrying could still qualify for exemption even if the farthest stop from the starting point did not have any road or highway system.
Secondly, in the last sentence of the last paragraph in your response to Question 4 you have written that it is fair to say that a service of ferrying between two provinces links two road systems. This seems to imply that if two provinces are linked by a service of ferrying by watercraft, regardless of whether there are road or highway systems on either side, then we will consider the service of ferrying to link two road or highway systems. The existence of provinces at the ends of a ferrying service is no substitute for the existence of parts of a road or highway system at the ends of a ferrying service. Provincial or municipal boundaries have no relevance for determining whether the supply of a service of ferrying is an exempt supply. There is no rationale for the statement in that sentence, I think it is incorrect as written and I recommend that it be amended or removed.
Response to Question 5
I agree with your comments.
Response to Question 6
I agree with your comments and appreciate your note that marshes, swamps and bogs could qualify as stretches of water in the case of a hovercraft and your earlier note that a hovercraft is included in the meaning of a watercraft.
Response to Question 7
I agree with your comments and I have made further comments under the heading of "Principal Purpose" earlier in this letter on approaches to use in determining the principal purpose when freight transportation services are added to the services on a ferry route.
Short Excursions
In the second last paragraph on page 5 of your draft letter, you have written that the service of ferrying on XXXXX will be considered to qualify for exemption because it uses the same boat and follows the same route on a pre-determined schedule as the service of ferrying provided on the other days. According to the facts provided, the XXXXX route is from Port A to Port B and back as shown on the diagram in Appendix I. The regular route is from Port A to Port B to Island C to Bay E and return.
Although the XXXXX route may follow part of the route of other days, I would not consider the XXXXX route to be the same route as the regular route since the regular route goes considerably further. A new evaluation of whether the XXXXX service meets the principal purpose test must be done because the XXXXX service is a different route and a different service of ferrying.
It is implied in the facts provided that there is a road system on the island on which Port B is located. Consequently, from the facts provided, I would agree with the conclusion that the XXXXX service of ferrying may be exempt, as is the regular service, but through a different reasoning. There is a different route for the XXXXX service, therefore, a different service of ferrying and that different service of ferrying appears to qualify as an exempt supply on its own.
In your draft interpretation the word "exonérées" has been spelt as "enonérées" in the fourth line of the first paragraph on the last page.
This concludes my comments on the draft interpretation letter prepared in your office. As you can easily see, there are many factors to consider in evaluating whether or not a supply of a service of ferrying qualifies as an exempt supply. The legislation allows for some flexibility and I have tried to provide the rationale, criteria and examples of extremes to illustrate the Department's policy.
I trust this letter has responded to all the questions to your satisfaction and regret the delay. If you have any comments or questions, please do not hesitate to contact Tom Alley, Tax Policy Officer, at (613) 952-9218.
Enikö Vermes
Manager
Health Care, Goods and Services Unit
Special Sectors
GST Rulings and Interpretations
Appendices I & II
| c.c.: |
Enikö Vermes
Adam Belyea
Tom Alley |
References: ETA subsections 123(1) & 165(1)
Section 1 of Part VIII of Schedule V to the ETA
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