CRA finds that delivery services supplied to a platform, which had contractual responsibility for the delivery to the purchasing consumer, were zero-rated

A platform contracted with delivery drivers to deliver goods to the consumers who had purchased goods on the platform.

CRA found that the delivery services supplied by the drivers to the platform were zero-rated under ETA s. VI-VII-11, which applies to a freight transportation service made by a carrier of the property to a second carrier of the property and zero-rates the second carrier’s fee. In particular, CRA indicated that “[f]or a person to be considered a 'carrier', the person need only assume liability as a supplier of a freight transportation service,” so that the platform was the first carrier even though it did not do any of the transporting.

Neal Armstrong. Summary of 20 June 2024 GST/HST Ruling 247341 under ETA s. VI-VII-11.