GST/HST Severed Letters - 2023-07

HST severed letters, 2023-07

GST/HST Ruling

12 July 2023 GST/HST Ruling 174441 - and GST/HST INTERPRETATION - Application of GST/HST on funds raised through crowdfunding

CRA Tags
ETA Part IX, 123(1),223(1),133,142(1),152(1)(c),168(1),232(2), New Harmonized Value-Added Tax System Regulations 6(1), 7, 11
if no contractual restrictions on place of use of IPP, the IPP is supplied in Canada
applicable specified province (regarding a non-zero-rated supply of IPP to a non-resident with unspecified address) was the one most proximate to the business office of the IPP supplier
factors relevant to determining whether GST inclusive or exclusive
s. 133 effectively deemed advance payments to be consideration for a taxable supply

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