1999 GST/HST Interpretation HQR0001565 - Status of Services Supplied by

Dear XXXXX

Thank you for your letter of January 19, 1999 (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the status of payments made to XXXXX[.] We have revisited your argument that the supervision of the sales representatives so as to ensure that they adhere to all regulatory requirements of the provincial securities commission as well as the sales practices and requirements of XXXXX, constitutes a financial service. Notwithstanding the necessity of a supervisory function, this role however, does not alter or change any contract for a product issued or distributed by XXXXX as set out in the agreements. Therefore, XXXXX not involved in providing a financial service but rather provides an important role in providing services that are an input to a financial service.

In conclusion, after reviewing the representations you have made, and the decisions issued to both firms by the region as well as discussing the issue with the region, we are in agreement with their position concerning this issue.

Should you have any further questions or require clarification on the above matter, please do not hesitate to contact J. Sitka at 613-952-9198.

Yours truly,

E.H. Gauthier
Director General
GST/HST Rulings & Interpretation Directorate