GST/HST Memorandum 17-12 [17.12] "Input Tax Credit Allocation Methods for Financial Institutions for Purposes of Section 141.02" 23 July 2021

S. 141.01(2) relevant to intended use of acquisitions (informed by actual use)

9. Subsection 141.02(1) defines procurative extent as the extent...

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Operative extent relevant to ITCs on improvements and change-in-use rules

10. Subsection 141.02(1) defines operative extent as the extent to...

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S. 150(1) election renders inputs to services rendered by electing FI to another group FI exclusive inputs

Example 4

Financial Institution D is a...

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Direct input where FI partially leases out office building rather than using in its financial business

Example 5

Financial Institution E makes...

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FIs have few non-attributable inputs

27. A financial institution generally has very few non-attributable inputs.

Example of (rare)...

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Hierarchy of methods

42. A meaningful ITC allocation method must be based:

• first, on tracking to the extent possible
• second, to the extent that...

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Change of use reflected in specified method applied to computer use

• Example (Example 13) of application of s. 206(3) so that a financial...

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FI precluded from using a different (causal) method in subsequent year

Example 15

Financial Institution O has allocated the cost of consulting...

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Implications of s. 141.02(9) election

100. Where an election under subsection 141.02(9) is in effect for a particular fiscal year for a financial...

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Example 2

• Contractor’s service to complete improvements to capital real property is an excluded input.