CRA rules that a fee charged on assigning receivables was part of the GST-exempt consideration for the receivables sale

A car dealer enters into contracts with customers, which could be conditional sales contracts, instalment sales contracts, credit agreements or finance contracts with instalments, and immediately sells each contract to a lender for cash consideration. Consistently with Canada Trustco, CRA found that a separate fee charged by the car dealer on selling the contracts was also part of the consideration for the assignment, so that the fee was also exempted from GST/HST.

Neal Armstrong. Summary of 21 December 2016 Ruling 157873 under ETA, s. 123(1) – financial service – (d).