8 June 2005 GST/HST Interpretation 61104 - Delivery requirements and relief of GST on property of an Indian or Indian band situated on a reserve

Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence.

Dear XXXXX:

Thank you for your XXXXX correspondence and telephone conversation concerning the application of the Goods and Services Tax (GST) to XXXXX movie packages purchased by you.

All legislative references are to the Excise Tax Act (ETA) and the regulations therein, unless otherwise specified.

We understand XXXXX that you have purchased XXXXX ("XXXXX Packs") from the website XXXXX. GST has been charged on the sale price XXXXX of the goods. The XXXXX Packs include the following:

•   XXXXX

•   XXXXX

•   XXXXX

•   XXXXX

•   XXXXX

•   XXXXX

•   While quantities last / Available for XXXXX online purchase only.

** XXXXX

You have indicated further that each XXXXX Coupon can be exchanged at any XXXXX box office for a ticket to your choice of a movie. The XXXXX website advertises the coupon as valid for 1 general admission at any XXXXX Theatre, including the XXXXX.

Interpretation Requested

You would like to know whether the GST was applied correctly to your purchase.

Interpretation Given

Based on the information provided, the subject XXXXX Packs are subject to GST at the rate of 7% calculated on the sale price of $XXXXX.

The foregoing comments represent our general views with respect to the subject matter of your request. These comments are not rulings and, in accordance with the guidelines set out in GST/HST Memorandum 1.4, Goods and Services Tax Rulings, do not bind the Canada Revenue Agency with respect to a particular situation. Future changes to the ETA, regulations, or our interpretative policy could affect this interpretation.

For your convenience, find enclosed a copy of GST/HST Memorandum 1.4, Goods and Services Tax Rulings.

If you require clarification with respect to any of the issues discussed in this letter, please call me directly at (613) 954-1433.

Yours truly,

Bao Tran
Specialty Tax Unit
Financial Institutions and Real Property Division
Excise and GST/HST Rulings Directorate

2005/06/30 — RITS 61582 — ITC Eligibility for GST/HST Payable