CRA expands its GST/HST Memorandum on Passenger Transportation Services

CRA has more than doubled its GST/HST Memorandum on passenger transportation.

Much of the additional material relates to expanding the discussion to include the provincial place-of-supply rules, covering some new rules, e.g., the revised municipal transit rules and the ride-sharing rules, and expanding the examples provided. It has ported some of its positions on the transportation zero-rating provisions into the place-of-supply arena, e.g., its positon that a scheduled stop of less than 24 hours generally will not be a “stopover.”

Neal Armstrong. Summaries of GST/HST Memorandum 28.3 Passenger Transportation Services July 2019 under ETA Sched. V, Pt. VI, s. 24, Sched. VI, Pt. VII, s. 1 – stopover, continuous journey, s. 2, s. 3, x s. 5, Sched. IX, Pt. VI, s. 4.1, New Harmonized Value-Added Tax System Regulations, s. 21, s. 22(1), s. 23, ETA s. 123(1) – taxi business.