9 March 2000 GST/HST Ruling 8375 - Application of the GST/HST to the Supply of Transcripts

Dear XXXXX

Thank you for your letter of September 22, 1999 (with attachments), concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the supply of XXXXX[.] Please note that as of November 1, 1999, Revenue Canada became the Canada Customs and Revenue Agency.

Statement of Facts

Our understanding of the facts is as follows:

1. XXXXX XXXXX[.]

2. XXXXX[.]

3. XXXXX[.]

4. Additional transcripts, over and above the five previously mentioned, cost XXXXX each.

5. The results of these tests are sent directly by XXXXX[.]

Ruling Requested

Is the supply of an XXXXX subject to GST or HST when it is mailed to a university in a harmonized province?

Ruling Given

The supply of an additional transcript is considered a service for GST/HST purposes. Therefore, notwithstanding that a transcript may be mailed to a university in a participating province, since the service is performed all or substantially all in a non-participating province XXXXX it will be subject to tax at the rate of 7%.

This ruling is subject to the general limitations and qualifications outlined in section 1.4 of Chapter 1 of the GST/HST Memoranda Series. We are bound by this ruling provided that none of the above issues is currently under audit, objection, or appeal; that there are no relevant changes in the future to the Excise Tax Act, or to departmental interpretative policy; and that you have fully described all necessary facts and transaction(s) for which you requested a ruling.

Explanation

Section 2 of Part V of Schedule IX to the ETA provides that, subject to Part IV and Parts VI to VIII of the Schedule, if all or substantially all of the Canadian element of a service is performed in a particular province, the service is regarded as made in that province. In the case at hand, the supply of additional transcripts will be subject to tax at the rate of 7% as the service is performed entirely in XXXXX which is a non-participating province.

Should you have any further questions or require clarification on the above matter, please do not hesitate to contact me at (613) 952-0329.

Yours truly,

Gabrielle Nadeau
Charities, NPO's and Education Unit
Public Service Bodies & Governments Division
Excise and GST/HST Rulings Directorate