18 October 2000 GST/HST Ruling 32212 - Relief of GST on Exported Goods

Dear XXXXX:

Thank you for your letter of July 29, 2000, concerning the application of the Goods and Services Tax (GST) to goods sent to you outside of Canada.

Statement of Facts

Our understanding of the facts is as follows:

You have acquired from XXXXX operating out of Toronto, Ontario, taxable goods that were sent to you by mail outside of Canada.

The goods were mailed by XXXXX to a Department and Foreign Affairs and International Trade (DFAIT) mailing address in Ottawa at XXXXX has charged you GST on its supplies of the goods that were mailed to you at such an address in Canada.

Ruling Requested

The shipments of the goods acquired from XXXXX and sent to you outside Canada through the DFAIT address in Canada are GST and/or PST exempt.

Ruling Given

Based on the facts set out above, we rule that goods acquired by a recipient that are sent by mail by the supplier to XXXXX), a DFAIT address, and which are ultimately exported from Canada are zero-rated (taxed at 0 per cent), pursuant to section 12 of Part V of Schedule VI to the Excise Tax Act.

With respect to the Ontario provincial retail sales tax, you may contact the Regional Retail Sales Tax Ottawa Office, at 300-1400 Blair Place, Gloucester, ON, K1J 9B8 or by calling their number at (613) 746-9200, for further information regarding the application of the Ontario retail sales tax.

This ruling is subject to the general limitations and qualifications outlined in section 1.4 of Chapter 1 of the GST/HST Memoranda Series. We are bound by this ruling provided that none of the above issues is currently under audit, objection, or appeal; that there are no relevant changes in the future to the Excise Tax Act, or to our interpretative policy; and that you have fully described all necessary facts and transaction(s) for which you requested a ruling.

Should you have any further questions or require clarification on the above matter, please do not hesitate to contact me at (613) 957-8220.

Yours truly,

Daniel E.B. Chamaillard
Senior Technical Analyst
Border Issues Unit
General Operations and Border Issues Division
Excise and GST/HST Rulings Directorate