File: 11860-2
C.N.: 2709
Dear XXXXX
This is in response to your fax transmission to Enikö Vermes of this office, dated January 30, 1996. In your fax you requested clarification on the application of the Goods and Services Tax (GST) to the supply of your product, XXXXX[.] As per your fax, the XXXXX is designed to prevent unnecessary bending of the hips and lower and upper back by persons with restricted movement including disabled persons, the elderly, pregnant women and those who suffer from arthritis or other physical limitations of movement. To this end, the XXXXX has been designed as a XXXXX with an approximately XXXXX inch long handle.
Pursuant to section 31 of Part II of Schedule VI to the Excise Tax Act, the Medical Devices (GST) Regulations lists certain classes of goods, the supply of which, is zero-rated for GST purposes. One of those classes of goods is as follows:
"(d) property that is specially designed to assist an individual in coping with or treating a chronic abnormal physical state of the individual, as follows,
... (ii) reaching aids, ..."
The XXXXX is considered to be a reaching aid within the parameters of this provision. The supply of the XXXXX is therefore zero-rated for GST purposes.
This ruling is given subject to the general limitations and qualifications outlined in the GST Memoranda Series 1.4. We are bound by this ruling provided that none of the above issues are presently under audit, objection or appeal, there are no relevant changes in the future to the Excise Tax Act and provided that you have described all necessary facts and transactions for which you requested a ruling.
If you would like to discuss this matter, please do not hesitate to contact Ken Syer, A/Senior Policy Officer, at (613) 952-9590.
Your truly,
J.A. Venne
Director
Special Sectors
GST Rulings and Interpretations
Policy and Legislation Branch
c.c.: M. Brule
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