Garage Gilles Roy – Tax Court of Canada finds that an emailed claim was not an invoice for GST purposes

Rendering an invoice generally triggers an obligation to collect GST. Claims for repair work done by a garage, which it emailed to the servicer of the manufacturer’s warranty, were found by Favreau J to not be invoices.  They did not crystallize a liability for the work as there was a real prospect that the charges would be rejected in whole or in part.  Instead, GST did not become payable until the claims were approved.

Neal Armstrong. Summary of Garage Gilles Roy (2007) Inc. v. The Queen, 2014 CCI 269 under ETA, s. 152(1).