ETA Part IX, 123(1)(consideration), 123(1)(debt security), 123(1)(financial instrument), 123(1)(financial service), 123(1)(supply), 123(1)(taxable supply), ETA Sch V, Part VII Sec. 1

Summary Under

Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Debt Security

a loan assimilated to a royalty agreement, so that "principal" advanced was taxable

Summary Under

Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply

loan and royalty advance were consideration for single taxable supply of IPP

2 May 2019 GST/HST Ruling 150998 - Fees charged in relation to project loans

CRA Tags

ETA Part IX, 123(1), 138, 139, 165, ETA Sch V, Part VII, SOR/91-26 Financial Services (GST) Regulations

Summary Under

Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4)

non-refundable fee paid by borrower to lender’s agent to perform due diligence and take the financing project through to closing were taxable preparatory services

Summary Under

Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.3)

predominant nature of fees paid to loan agent was for loan management

Summary Under

Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l)

fee paid for taking a financing from signing through to closing is taxable

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2024

June	18
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January	31

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December	25
November	3
October	6
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July	2
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May	5
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March	3
February	11
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2022

December	6
November	6
October	5
September	3
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June	5
April	15
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2021

November	2
October	10
September	3
August	9
July	2
June	4
May	4
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March	3
February	5
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2020

December	4
November	4
October	2
September	2
August	5
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June	1
March	2
February	1
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2019

December	4
November	2
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August	9
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May	11
April	5
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2018

December	6
November	1
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July	3
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March	11
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2017

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November	2
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2016

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2015

December	3
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October	7
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July	11
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December	4
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2013

December	5
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2012

December	9
November	15
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July	14
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2011

December	10
November	11
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August	23
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2010

December	13
November	15
October	9
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2009

December	12
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July	16
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April	9
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2008

December	18
November	18
October	11
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July	15
June	10
May	11
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March	17
February	15
January	13

2007

December	22
November	15
October	11
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August	9
July	30
June	11
May	22
April	15
March	15
February	15
January	13

2006

December	10
November	11
October	13
September	41
August	16
July	10
June	24
May	14
April	19
March	21
February	22
January	27

2005

December	10
November	9
October	19
September	11
August	12
July	12
June	17
May	7
April	17
March	17
February	14
January	18

2004

December	18
November	12
October	13
September	22
August	26
July	23
June	23
May	15
April	15
March	26
February	9
January	10

2003

December	20
November	10
October	20
September	12
August	21
July	36
June	28
May	26
April	17
March	48
February	24
January	30

2002

December	36
November	19
October	21
September	19
August	30
July	27
June	23
May	20
April	6
March	21
February	10
January	24

2001

December	10
November	10
October	17
September	11
August	14
July	14
June	9
May	1
April	6
March	49
February	20
January	13

2000

December	11
November	13
October	28
September	25
August	23
July	42
June	31
May	21
April	22
March	53
February	17
January	30

1999

December	37
November	13
October	6
September	23
August	15
July	10
June	29
May	27
April	15
March	26
February	25
January	20

1998

December	46
November	35
October	45
September	54
August	38
July	44
June	30
May	32
April	28
March	34
February	16

1997

November	23
October	22
September	18
August	12
July	27
June	17
May	22
April	24
March	8
February	28
January	18

1996

December	16
November	15
October	17
September	9
August	32
July	9
June	19
May	25
April	19
March	46
February	25
January	31

1995

December	14
November	27
October	19
September	14
August	24
July	25
June	25
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April	11
March	28
February	35
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1994

December	4
November	10
October	10
September	18
August	36
July	15
June	9
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April	9
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February	15
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1993

November	1
January	1

1992

November	1
March	1
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GST/HST Severed Letters - 2019-05

HST severed letters, 2019-05

Excise Ruling

GST/HST Interpretation

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