Ontario College of Teachers – Tax Court of Canada finds that a GST/HST exemption for providing certificates does not cover an evaluation service culminating in the certificate

Sched. V, Pt. VI, s. 20(d) (which was similar to the current version of the provision) would have provided an HST exemption for the supply by the Ontario College of Teachers of "a service of providing information in respect of, or any certificate…evidencing…any status of any person."  Jorré  J found that the charges of the College in examining the training and credentials of prospective Ontario teachers were essentially for an evaluation service rather than a service of issuing a certificate, even though a successful candidate received a certificate at the end of the process.  Accordingly, those charges were not exempt.

This approach is similar to the single supply doctrine, under which an ancillary component gets subsumed into what predominantly is supplied (see Calgary, Hidden Valley, OA Brown).

Neal Armstrong.  Summary of Ontario College of Teachers v. The Queen, 2014 TCC 130 under ETA - Sched. V, Pt. VI, s. 20(d).