Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada.
GST/HST Rulings Directorate
5th floor, Tower A, Place de Ville
320 Queen Street
Ottawa ON K1A 0L5
[Addressee]
Case Number: 247650
Dear [Client]:
Subject: GST/HST INTERPRETATION
Public Service Body Rebate for […][a Hospital Authority resident in a participating province in Canada]
Thank you for your request for information regarding the Public Services Bodies (PSB) Rebates available to […][a hospital authority resident in a participating province in Canada]. A hospital authority is an organization that operates a public hospital and that is designated by the Minister of Revenue as a hospital authority for the purposes of Part IX of the Excise Tax Act (ETA).(Footnote 1)
This letter will provide information on the PSB rebates available to […][a hospital authority] for the GST and the federal part of the HST and for the provincial part of the HST. The rate of the PSB rebate depends on the type of activities engaged in by the hospital authority […]
You will find our response presented in the following manner:
1. PSB Rebate of the GST and federal part of the HST
1. 1 Operating a public hospital
1. 1.1 Public Hospital
1. 1.2 Activities of operating a public hospital
1. 2 PSB Rebate for other health care services
1. 2.1 Operating a qualifying facility for use in making facility supplies
1. 2.1.1 Qualifying facility
1. 2.1.2 Facility supply
1. 2.2 Ancillary supply
1. 2.3 Home medical supply
1. 2.4 Medical funding
1. 3 […]
2. Rebate of the provincial part of the HST
3. Additional information on the calculation of the PSB rebate
3. 1 Apportionment
3. 2 All or substantially all
1. PSB Rebate of the GST and federal part of the HST
Certain public service bodies, such as hospital authorities, can claim a PSB rebate to recover a percentage of the GST/HST paid or payable on eligible purchases and expenses. Hospital authorities are eligible to claim a PSB rebate at the rate of 83% of the GST and the federal part of the HST where applicable. The 83% PSB rebate rate applies to non-creditable tax charged for property and services acquired by the hospital authority. Non-creditable tax charged is generally the GST/HST that was paid or payable by the hospital authority, that cannot be recovered through an input tax credit, or any other rebate, refund or remission.(Footnote 2)
[…][As a registered charity that is a hospital authority, the hospital authority is also a public institution], as defined in subsection 123(1), […]. […][Because the hospital authority is a public institution, the] supplies of personal property or services [made by the hospital authority] would generally be exempt under section 2 of Part VI of Schedule V. Section 2 of Part II of Schedule V exempts a supply of an institutional health care service made by the operator of a health care facility if the institutional health care service is rendered to a patient or resident of the facility. The terms “institutional health care service” and “health care facility” are defined in section 1 of Part II of Schedule V. Section 2 of Part II of Schedule V may also apply to exempt supplies of services made by the […][hospital authority]. GST/HST incurred in activities of making of exempt supplies generally falls under non-creditable tax charged as it cannot be recovered through an input tax credit.
An organization that operates a public hospital and that has been designated as a hospital authority may apply for an 83% rebate of the GST or the federal part of the HST on purchases and expenses incurred in activities carried on in the course of operating a public hospital, of operating a qualifying facility for use in making facility supplies or of making facility supplies, ancillary supplies or home medical supplies. The terms “activities of operating a public hospital”, “qualifying facility”, “facility supplies”, “ancillary supplies”, and “home medical supplies” are explained below.
1.1 Operating a public hospital
1.1.1 Public Hospital
We understand that the […][hospital authority operates] a number of different facilities. It is important to note that not all facilities that are called hospitals or that are classified as a hospital by provincial legislation are “public hospitals” for GST/HST purposes. For the purposes of the ETA, a public hospital is a building, or group of buildings under a common corporate structure operated to provide medical or surgical treatment for the sick or injured, including acute, chronic or rehabilitative care.(Footnote 3)
A public hospital encompasses all of the following characteristics:
* The services of medical practitioners, nursing staff and allied health professionals are available at all times to carry out the examination and diagnosis of patients and the provision of medical or surgical treatment and care.
* The services of health care personnel and health care equipment are utilized for the provision of health care services to the general public. This includes accommodation for laboratory, radiological and other diagnostic services, the administration of drugs, the use of operating rooms, case rooms, medical or surgical supplies and equipment.
* In-patient beds and services are provided. Patients are assigned a bed in order to receive diagnostic services, medical treatment and care. In-patient services are also provided in the public hospital to ensure the patient's necessities of life and comfort, these include nursing services on a 24-hour basis, food services and laundry services.
* Operational and capital funding is received from provincial or territorial governments for the provision of publicly insured in-patient and out-patient hospital services.
* The hospital authority operates the public hospital under the laws of a provincial or territorial government respecting hospitals.
To be considered a public hospital for purposes of the PSB rebate, a facility must have health care personnel and health care equipment available to provide health care services to the general public. There must be the administration of drugs, the provision of laboratory, radiological and other diagnostic services, the use of operating rooms, medical or surgical supplies and equipment and physicians, nursing staff and other health care professionals must be present 24 hours a day / 7 days a week.
A facility that does not have all these characteristics is not a public hospital for purposes of the ETA. For example, a long-term care facility that provides 24-hour nursing care and supervision, including assistance with daily activities, medication assistance and social and recreational activities but that does not provide diagnosis and treatment of injuries or disease and does not have physicians or nurse practitioners present at all times would not qualify as a public hospital.
The hospital authority designation applies to the organization as a whole but that does not mean that all of the facilities operated by the hospital authority are “public hospitals”. Activities undertaken by a hospital authority in respect of a facility that is not a public hospital would not be considered to be activities of operating a public hospital.
1.1.2 Activities of operating a public hospital
A hospital authority may claim an 83% rebate of the GST and the federal part of HST to the extent its purchases and expenses can be related to activities of operating a public hospital. The term “activities of operating a public hospital” is not defined in the ETA. The structure of the legislation and the requirement to apportion rebates makes it clear that not everything done by a hospital authority will be in the course of operating a public hospital. The CRA has developed an administrative policy for purposes of administering this rebate.
We consider activities of operating a public hospital to be activities related to the provision of patient care. These are the activities for which a person is designated as a “hospital authority”. For purposes of the rebate, we consider a “patient” to be an individual who receives care and treatment in a public hospital, including diagnostic and/or therapeutic services, and who appears in the hospital’s registry or other official record as a patient. This includes both inpatients who are admitted to a public hospital and allocated an inpatient bed and outpatients who are provided treatment on an ambulatory basis.
Patient care is care provided to inpatients and outpatients. This will include the use of medical and surgical equipment, operating rooms, drugs, accommodation and meals, laboratory, diagnostic procedures and rehabilitative services.
We also consider the following to be related to patient care if provided by the hospital authority:
* teaching services in the hospital,
* patient transportation services on admission or upon discharge,
* programs identified as falling under the operational plan of the public hospital such as outpatient educational services, pastoral care and other patient and family support services,
* the provision of toys and play activities for children,
* services provided by social workers and patient discharge assistance.
In operating the public hospital, the hospital authority will also acquire property and services for its own use in activities related to patient care. Examples are: fund-raising activities for its own use, medical libraries, records keeping, housekeeping services, maintenance services and custodial services, materiel and facilities management, security services and staffing and human resource activities. These will be eligible for the 83% rebate of the GST and the federal part of the HST based on the extent to which the purchases and expenses are incurred in activities related to patient care.
For more information on activities carried on in the course of operating a public hospital, see GST/HST Policy Statement P-245, Determination of “…activities engaged in by the person in the course of operating a public hospital” for purposes of the 83% public service body rebate for hospital authorities at https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/p-245.html
1.2 PSB Rebate for other health care services
In addition to the PSB rebate in respect of operating a public hospital a hospital authority is also eligible to claim an 83% PSB rebate of the GST and the federal part of the HST in respect of certain other health care services. Activities such as medical care provided to individuals in their homes as well as support activities provided to public hospitals and to certain health care facilities may also be eligible for the 83% rebate of the GST and the federal part of the HST.
A hospital authority is also entitled to claim a 83% rebate of the GST and the federal part of the HST in respect of activities engaged in the course of operating a qualifying facility for use in making facility supplies or of making facility supplies, ancillary supplies and home medical supplies in addition to its activities of operating a public hospital.
The terms “qualifying facility”, “ancillary supply”, “facility supply”, and “home medical supply” are all defined in the ETA. Below we will discuss the meaning of each of the terms.
1.2.1 Operating a qualifying facility for use in making facility supplies
A hospital authority is entitled to apply for an 83% rebate of the GST or federal part of the HST paid or payable on eligible purchases and expenses for consumption, use or supply in activities engaged in by the person in the course of operating a qualifying facility for use in making facility supplies.
In order to determine the [hospital authority]’s entitlement to a rebate in respect of these activities it is necessary to identify which of the facilities that the [hospital authority] operates are qualifying facilities. The definition of “qualifying facility” in subsection 259(2.1) sets out three criteria that must be met for a facility, or part of a facility, to be a qualifying facility. Meeting these criteria establishes that a facility or part of a facility, other than a public hospital, will be considered a qualifying facility for a fiscal year, or any part of a fiscal year, of the operator of the facility or part.
1.2.1.1 Qualifying facility
A facility or part of a facility will be considered a “qualifying facility” if:
(a) supplies of services that are ordinarily rendered during that fiscal year or part to the public at the facility or part would be facility supplies if the references in the definition “facility supply” in subsection 259(1) to “public hospital or qualifying facility” were references to the facility or part;
(b) an amount, other than a nominal amount, is paid or payable to the operator as qualifying funding in respect of the facility or part for the fiscal year or part; and
(c) an accreditation, licence or other authorization that is recognized or provided for under a law of Canada or a province in respect of facilities for the provision of health care services applies to the facility or part during that fiscal year or part.
Therefore, for a facility to be a “qualifying facility”, facility supplies must be rendered at the facility, the operator of the facility must receive qualifying funding, and there must be a federal or provincial accreditation, licence or authorization for the provision of health care services at the facility.
The first element of the definition of “qualifying facility” is that supplies of services ordinarily rendered at the facility must be facility supplies. Where facility supplies are ordinarily rendered in a facility, that facility would meet the requirements of paragraph (a) of the definition of “qualifying facility”. The concept of facility supply will be explained in more detail below.
Paragraph (b) of the definition of “qualifying facility” in subsection 259(2.1) outlines the second condition the claimant must meet in regards to the facility. Paragraph (b) requires that an amount, other than a nominal amount, be paid or payable to the operator of the facility as “qualifying funding” in respect of the facility or part.
Subsection 259(1) defines “qualifying funding” of the operator of a facility for all or part of a fiscal year of the operator to mean "a readily ascertainable amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the operator in respect of the delivery of health care services to the public for the purpose of financially assisting in operating the facility during the fiscal year or part, as consideration for an exempt supply of making the facility available for use in making facility supplies at the facility during the fiscal year or part or as consideration for facility supplies of property that are made available, or services that are rendered, at the facility during the fiscal year or part and is paid or payable by
(a) a government, or
(b) a person that is a charity, a public institution or a qualifying non-profit organization
(i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and
(ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person that are in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made.
It is our understanding that the […][hospital authority] receives more than 90% of its funding from […][the provincial government]. The funding from the province includes payments for hospital services, addiction and mental health, public health, and payments for physicians. This funding meets the requirements of the definition of “qualifying funding” as the funding provided is a readily ascertainable amount of money paid or payable in respect of the delivery of health care services to the public.
As the […][hospital authority is] receiving qualifying funding in respect of their facilities the second condition for qualifying facilities would be met.
Paragraph (c) of the definition of “qualifying facility” in subsection 259(2.1) outlines the third condition that the claimant must meet. Paragraph (c) requires the facility to have an accreditation, licence or other authorization that is recognized or provided for under a law of Canada or a province in respect of facilities for the provision of health care services.
[…]
This third condition would also be met by the [hospital authority]. As the second and third conditions of for qualifying facility have been met, a facility, or parts thereof, where facility supplies are ordinarily rendered would be qualifying facilities for purposes of the PSB rebate.
The definition of “qualifying facility” references a facility or part of a facility, this means that if only a part of a facility meets the conditions in the definition of “qualifying facility” it is that part of the facility that is a qualifying facility and not the whole facility. Therefore, where the [hospital authority] is using a building for multiple programs it will be necessary to look at each of the programs to determine if the part of the facility used for that program is a qualifying facility.
The definition of “qualifying facility” in subsection 259(2.1) is to be applied on a facility-by-facility basis. Each facility operated by the [hospital authority] should be evaluated independently from other facilities to determine if that facility, or part of that facility, is a qualifying facility. The [hospital authority], as a hospital authority, would be entitled to claim an 83% rebate of the GST or federal part of the HST paid or payable on eligible purchases and expenses for consumption, use or supply in activities engaged in by the [hospital authority] in the course of operating a qualifying facility for use in making facility supplies.
1.2.1.2 Facility Supply
Subsection 259(1) defines the term “facility supply” to mean an exempt supply (other than a prescribed supply) of property or a service in respect of which:
(a) the property is made available, or the service is rendered, to an individual at a public hospital or qualifying facility as part of a medically necessary process of health care for the individual for the purpose of maintaining health, preventing disease, diagnosing or treating an injury, illness or disability or providing palliative health care, which process
i. is undertaken in whole or in part at the public hospital or qualifying facility,
ii. is reasonably expected to take place under the active direction or supervision, or with the active involvement, of
(A) a physician acting in the course of the practise of medicine,
(B) a midwife acting in the course of the practise of midwifery,
(C) a nurse practitioner acting in the course of the practise of a nurse practitioner, or
(D) a prescribed person acting in prescribed circumstances, and
iii. in the case of chronic care that requires the individual to stay overnight at the public hospital or qualifying facility, requires or is reasonably expected to require that
(A) a registered nurse be at the public hospital or qualifying facility at all times when the individual is at the public hospital or qualifying facility,
(B) a physician or a nurse practitioner, be at, or be on-call to attend at, the public hospital or qualifying facility at all times when the individual is at the public hospital or qualifying facility,
(C) throughout the process, the individual be subject to medical management and receive a range of therapeutic health care services that includes registered nursing care, and
(D) it not be the case that all or substantially all of each calendar day or part during which the individual stays at the public hospital or qualifying facility is time during which the individual does not receive therapeutic health care services referred to in clause (C), and
(b) if the supplier does not operate the public hospital or qualifying facility, an amount, other than a nominal amount, is paid or payable as medical funding to the supplier.
Therefore, to be a facility supply, a supply must meet the following criteria:
* it must be an exempt supply of property or service that is made available or rendered to an individual in a public hospital or qualifying facility;
* the exempt supply of property or service must be part of a medically necessary process of health care for the individual for the purpose of maintaining health, preventing disease, diagnosing or treating an injury, illness or disability or providing palliative health care;
* the medically necessary process of health care must be undertaken at the public hospital or qualifying facility;
* the medically necessary process of health care is reasonably expected to take place under the active direction or supervision, or with the active involvement, of a physician, a midwife acting in the course of the practise of midwifery, or a nurse practitioner acting in the course of the practise of a nurse practitioner;
* if an individual is receiving chronic care and stays overnight at the public hospital or qualifying facility, the hospital or facility must have a registered nurse present at all times and a physician or nurse practitioner present or on call at all times whenever an individual is there. In addition, the individual must be receiving medical management and receive at least 2.4 hours per day of therapeutic health care that includes registered nursing care each day; and,
* if the supplier does not operate the public hospital or qualifying facility an amount is paid or payable as medical funding to the supplier.
Facility supplies for purposes of this rebate means that physicians or nurse practitioners are actively involved in the medically necessary process of health care for the individual, e.g., diagnosing and treating an injury, illness or disability; performing surgery, providing treatment, and actively monitoring the individual's condition. The medical condition and level of care required of individuals must be such that it calls for active physician involvement to respond to their health care needs. Examples of facilities where such care is rendered are cancer clinics, day surgery clinics, hemodialysis clinics, community health centres that render primary care services to the public as well as certain long-term care homes.
1.2.2 Ancillary Supply
An ancillary supply is:
a) an exempt supply of organizing or coordinating the making of facility supplies or home medical supplies for which an amount (other than a nominal amount) is payable to the supplier as medical funding, or
b) the portion of an exempt supply (other than a facility supply or home medical supply) of a property or service that represents the extent to which the property or service is or is reasonably expected to be used or consumed for making a facility supply and for which portion, an amount (other than a nominal amount) is paid or payable to the supplier as medical funding.
For a particular supply to be an ancillary supply, the supply must be an exempt supply that is described in paragraph (a) or (b) of the definition, and an amount must be paid or payable to the supplier as “medical funding”.
Paragraph (b) of the definition of “ancillary supply” provides, in part, that an ancillary supply means the portion of the exempt supply of property or service that represents the extent of the property or service that is, or reasonably expected to be, consumed or used for making a facility supply. Therefore, for an exempt supply (or a portion of an exempt supply) of property or service to qualify as an ancillary supply, the property or service must be consumed or used for making a supply that is a “facility supply”, as that term is defined.
[…]
1.2.3 Home Medical Supply
A home medical supply is an exempt supply of a property or service that is:
* made as part of a medically necessary process of health care for an individual for the purpose of maintaining health, preventing disease, diagnosing or treating an injury, illness or disability or providing palliative care where a physician or nurse practitioner has identified or confirmed that it is appropriate for the process to take place at the individual’s place of residence or lodging (other than a public hospital or qualifying facility),
* the property is made available, or the service is rendered, to the individual at the individual’s place of residence or lodging (other than a public hospital or a qualifying facility), on the authorization of a person who is responsible for coordinating the process and under circumstances in which it is reasonable to expect that the person will carry out that responsibility in consultation with, or with ongoing reference to instructions for the process given by, a physician acting in the course of the practise of medicine or a nurse practitioner acting in the course of the practise of a nurse practitioner,
* all or substantially all of which is of property or a service other than meals, accommodation, domestic services of an ordinary household nature, assistance with activities of daily living and social, recreational and other related services to meet the psycho-social needs of the individual, and
* an amount (other than a nominal amount) is paid or payable as medical funding to the supplier.
As noted above, the definition of home medical supply provides that the property and/or services must be part of a medically necessary process of health care for the individual for the purpose of maintaining health, preventing disease, diagnosing or treating an injury, illness or disability or providing palliative health in consultation with, or pursuant to instructions given by, a physician or a nurse practitioner.
The definition also provides that all or substantially all of the supply must be something other than meals, accommodation, domestic services of an ordinary household nature, assistance with activities of daily living and social, recreational and other related services to meet the psycho-social needs of the individual.
For purposes of the ETA, we interpret the phrase “all or substantially all” to mean 90% or more. Therefore, looking at the totality of the supply of property and/or services that are provided to an individual in his or her home, if 10% or more of that supply includes homemaker or personal support services, those services will disqualify the supply from being a home medical supply. Homemaker and personal support services involve domestic services of an ordinary household nature and assistance with activities of daily living; these services are excluded from the definition of home medical supply.
[…]
1.2.4 Medical Funding
The term “Medical funding” is used in the definitions of ancillary supply, facility supply and home medical supply. Medical funding of a supplier in respect of a supply means an amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the supplier in respect of health care services for the purpose of financially assisting the supplier in making the supply or as consideration for the supply by
(a) a government, or
(b) a person that is a charity, a public institution or a qualifying non-profit organization
(i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and
(ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made.
Paragraph (b) of the definition of “medical funding” in subsection 259(1) includes a charity, public institution, or qualifying non-profit organization that has as one of its purposes the organization or coordination of the delivery of health care services to the public, and in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made.
The funding that the [hospital authority] receives from the [provincial government] meets the requirements of the definition of “medical funding” as the funding provided is a readily ascertainable amount of money paid or payable in respect of the delivery of health care services to the public.
1.3 […]
[...]
2. Rebate of the provincial part of the HST
[…]
Additionally, a hospital authority [that is] resident in […][a participating province in Canada and ] that is also a public institution is generally entitled to claim a […]% rebate of the provincial part of the HST paid on expenses incurred in exempt activities other than of operating a public hospital. Therefore, the [hospital authority] will have to identity the property and services used or consumed in each its activities and then apply the applicable rebate rates to the GST or federal and provincial parts of the HST paid or payable on these purchases and expenses.
3. Additional information on the calculation of the PSB rebate
Section 259 provides that a PSB rebate is calculated and claimed on a claim period by claim period basis. The claim periods of a GST/HST registrant are the same as the reporting periods for its GST/HST returns (i.e., annually, quarterly or monthly).
A PSB claims its rebate on a property-by-property or service-by-service basis. It is the intended consumption, use or supply of a particular property or service at the relevant time that determines the PSB rebate entitlement for the non-creditable GST or HST paid on that property or service, not the overall activities of the PSB. Generally, the relevant time will be the time the supply was made to, or the property was imported or brought into [the participating province] by the [hospital authority].
3.1 Apportionment
As required by subsection 259(4.1), the [hospital authority] will be required to apportion its rebate claims between its inputs that are for consumption, use or supply in its activities carried on in the course of operating a public hospital, operating a qualifying facility for use in making facility supplies or in the course of making facility supplies, ancillary supplies or home medical supplies, and its other activities, unless subsection 259(14) applies.
3.2 All or substantially all
Pursuant to subsection 259(14), where all or substantially all (90% or more) of the non-creditable tax charged in respect of property or a service for a claim period is tax incurred in its capacity as a hospital authority, the [hospital authority] will be entitled to claim an 83% PSB rebate on all of the non-creditable tax charged in respect of the property or service for that claim period. In other words, where the [hospital authority] incurs 90% or more of the GST/HST paid or payable on a property or a service for a claim period in its capacity as a hospital authority, all of the GST/HST charged in respect of the property or service for that claim period is deemed to have been incurred in that capacity.
As such, the [hospital authority] could claim a PSB rebate on all of the non-creditable tax charged in respect of the property or service for that claim period. For example, if the [hospital authority] incurs GST/HST on utilities for a facility that is used as a public hospital and a public health office in a claim period, and […][90% or more] of the use of the utilities for that facility is for activities of operating a public hospital, the [hospital authority] may claim the PSB rebate for all of the GST/HST it pays on the utilities using the 83% rebate rate for the GST and federal part of the HST and […]% of the provincial part of the HST.
However, if the facility was used as a community health centre and public health office and 93% of the use of the utilities is for operating a qualifying facility (the community health centre) for use in making facility supplies, the [hospital authority], as a hospital authority resident in [the province], may claim the PSB rebate for all of the GST/HST it pays on the utilities and the following rates:
(i) 83% of the GST and federal part of the HST, and
(ii) […]% of the provincial part of the HST.
If less than 90% of non-creditable tax charged in a claim period is for these purposes, [the hospital authority] is entitled to claim a PSB rebate at the appropriate rate to the extent the property or service is used for activities engaged in by the [hospital authority] in the course of operating a public hospital, operating a qualifying facility for use in making facility supplies, or in the course of making of facility supplies, ancillary supplies or home medical supplies at the appropriate rebate rate.
For more information on the calculation of the rebate in general, please refer to Guide RC4034, GST/HST Public Service Bodies' Rebate.
Finally, as a hospital authority, the [hospital authority] is responsible for informing the CRA of any changes that may affect its status as a hospital authority under the ETA. This may include a change in the activities undertaken at the facility, an amalgamation or merger, or the organization ceasing to be a non-profit organization or a registered charity.
If you have any questions or require clarification regarding PSB rebates available to hospital authorities as discussed in this letter, please contact Chantal Desrosiers, Manager, Health Care Sectors Unit, at 343-552-7297, or Art Blommesteijn at 343-573-6076. Should you have additional questions on the interpretation and application of GST/HST, please contact a GST/HST Rulings officer at 1-800-959-8287.
Yours truly,
Carol Gaudet
Director
Public Service Bodies and Governments Division
Excise and GST/HST Rulings Directorate
FOOTNOTES
1 Subsection 123(1) of the Excise Tax Act (ETA) and GST/HST Memorandum 25-2, Designation of hospital authorities.
2 Refer to GST/HST Memorandum 13-5 for more information on non-creditable tax charged: Non-creditable Tax Charged - Canada.ca
3 Refer to P-245, Determination of "...activities engaged in by the person in the course of operating a public hospital" for purposes of the 83% public service body rebate for hospital authorities
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