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Excise and GST/HST Rulings Directorate
Place de Ville, Tower A, 15th floor
320 Queen Street
Ottawa ON K1A 0L5XXXXX
XXXXX
XXXXX
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Case Number: 37534Business Number: XXXXXOctober 30, 2001
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Subject:
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GST/HST Interpretation - Sale of Squabs
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Dear XXXXX:
This is a follow-up to our letter of June 30, 2000 concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the sale of squabs (young unfledged pigeons that are normally harvested for meat between 3 and 4 weeks of age).
Interpretation Requested
In your letter of July 19, 1999, XXXXX, you indicated that part of the operation of your agricultural business includes the production of squabs that are supplied to an abattoir for processing, packaging and sale to restaurants. You required confirmation that the supply of the live squab to the abattoir was a zero-rated supply under section 1 of Part IV of Schedule VI to the Excise Tax Act (ETA).
In reply to your query, we indicated that the supply was not zero-rated and therefore would be subject to tax at 7 or 15 percent.
Interpretation Given
The purpose of this letter is to inform you of the change in our interpretative position regarding the application of the GST/HST to squabs.
Upon further review we consider squabs to be ordinarily raised as food for human consumption; therefore, the supply of squab is zero-rated under section 1 of Part IV of Schedule VI to the ETA.
The foregoing comments represent our general views with respect to the subject matter of your letter. Proposed amendments to the Excise Tax Act, if enacted, could have an effect on the interpretation provided herein. These comments are not rulings and, in accordance with the guidelines set out in section 1.4 of Chapter 1 of the GST/HST Memoranda Series, do not bind the Canada Customs and Revenue Agency with respect to a particular situation.
For your convenience, find enclosed a copy of section 1.4 of Chapter 1 of the GST/HST Memoranda Series.
Should you have any further questions or require clarification on the above matter, please do not hesitate to contact me at (613) 952-8532.
Yours truly,
Dwayne Moore
Goods Unit
General Operations and Border Issues Division
Excise and GST/HST Rulings Directorate
| c.c.: |
XXXXX
Gail Mason, Ministerial Unit, HQ
L. McAnulty
D. Moore |
Encl.:
| Legislative References: |
Section 1/Part IV/Schedule VI |
| NCS Subject Code(s): |
I 11845-2 |
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