4 January 2000 GST/HST Ruling 13362 - Application of the GST/HST to the Supply of Saliva Testing Strips (Kit)

Dear Sir:

This is in reply to your letter of July 19, 1999, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the supply of a kit consisting of a saliva testing strips product called XXXXX[.]

Statement of Facts

Our understanding of the facts is as follows:

1. XXXXX.

2. XXXXX[.]

3. XXXXX.

4. XXXXX.

Ruling Requested

The supply of XXXXX is zero-rated pursuant to section 29 of Part II of Schedule VI to the Excise Tax Act ("ETA").

Ruling Given

Based on the facts set out above, we rule that the supply of XXXXX XXXXX is not zero-rated for GST/HST purposes pursuant to [s]ection 29 of Part II of Schedule VI to the ETA. The supply of the strips is taxable for GST/HST purposes at the rate of 7%, or where the supply occurs in a participating province, 15%.

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 XXXXX

Section 29 of Part II of Schedule VI to the ETA provides zero-rated status to the supply of blood-sugar testing strips, blood-ketone testing strips, urinary-sugar testing strips, reagents or tablets, or urinary-ketone testing strips, reagents or tablets. According to the information that you have provided, XXXXX XXXXX. Consequently, [s]ection 29 of Part II of Schedule VI is not applicable to the supply of XXXXX[.] Should you have any further questions or require clarification on the above matter, please do not hesitate to contact me at (613) 954-3158.

Yours truly,

Michel Guay
Municipalities and Health Care Services Unit
Public Service Bodies and Governments Division

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