16 June 1999 GST/HST Interpretation HQR0001752 - Application of the GST/HST to the Supply of Repair Service

I refer to your e-mail message of April 22, 1999, (with attachments), addressed to Ms. Alyson Trattner, Manager, Good Unit, and your facsimile message of April 23, 1999, addressed to Mr. Randy Nanner, Manager, Border Issues Unit, concerning the application of the Harmonized Sales Tax (HST) XXXXX[.] I understand that:

XXXXX

•   When XXXXX[.] The items that go into the repair are essentially the same that go into building (manufacturing) XXXXX

•   In addition, when XXXXX require a replacement or changes XXXXX, the same items mentioned above may be used.

XXXXX is inquiring as to whether or not the parts, which are supplied XXXXX are subject to the HST.

As requested, I have reviewed your proposed response to XXXXX and am pleased to provide the following comments.

When XXXXX considered to be making a single supply of a repair service. The materials (e.g., parts) supplied in conjunction with the repair service are not considered to be a separate supply but, rather, one of the elements of the repair service. Your proposed response to XXXXX should, therefore, be revised to indicate that XXXXX making a single supply of a repair service.

There are no provisions in Schedule VI, Part IV to the Excise Tax Act (Act) or the XXXXX[.] Therefore, as the supply of the repair service is deemed, under the provisions of Schedule IX, Part V, paragraph 2(a) to the Act and section 144.1 of the Act, to be made in a participating province, the supply would be subject to the HST at 15%.

Should you have any further questions or require clarification on the above matter, please do not hesitate to contact me at (613) 952-6743.

Garry L. Ryhorchuk
Technical Officer
Border Issues Unit
General Operations and Border Issues Division
GST/HST Rulings and Interpretations Directorate