CRA indicates that a financial institution’s issuing shares and paying dividends to non-resident shareholders may be a zero-rated supply

CRA indicated that the issuance of shares and the payment of dividends by a financial institution to its non-resident shareholders could potentially qualify as zero-rated supplies, with the implication that GST on related inputs could be creditable. CRA considered that reporting to the shareholders and managing shareholder meetings were not a supply to the shareholders and, instead, represented inputs incurred in the institution’s operations.

Neal Armstrong. Summaries under of 17 December 2015 Interpretation 153009 under ETA, Sched. VI, Part IX, s. 1, ETA s. 123(1), financial service, para. (f), and ETA s. 123(1) – supply.