CRA notes GST/HST distinction between the supply of timber harvesting rights and of timber harvesting services

ETA, s. 162(2)(a) deems the supply of a right to exploit a forestry resource not to be a supply. However, CRA considers that "a person who merely agrees to cut down trees belonging to another is not the recipient of a supply of a right to exploit the resource; they are the supplier of a [taxable] service of cutting trees." Conversely, the recipient of a s. 162 right acquires title to the harvested trees at the moment of their felling rather than such title remaining with the other party.

Neal Armstrong. Summary of 6 June 2014 Interpretation 150533 under ETA, s. 162(2).