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EXPLANATION Ruling #1 – Characterization of the supply The characterization of a supply depends on the consideration of all relevant facts. ... Finally, the consideration for participating in the Program is paid as a lump sum, in full, before the date of the first workshop, and encompasses all elements of the Program without the elements being separately identified. ...

As such, the consideration for the supply is not subject to the GST/HST. ... As such, the consideration paid for the supplies is not subject to the GST/HST. ...

INTERPRETATION REQUESTED You wish to confirm that, given the specific facts set out in your [mm/dd/yyyy] submission, the service provided by Dealers as consideration for commissions under the financing contracts constitutes a “financial service” as defined in subsection 123(1) of the ETA. ... A fee or commission received by a Dealer from the financial institution for the assignment of an agreement which includes the Dealer’s right to receive a stream of payments from a customer, such as a conditional sales contract, installment sales contract, or credit agreement, would form part of the consideration received from the assignment of the agreement, and would not be subject to GST/HST where the assignment of the agreement is exempt. ...

RULING GIVEN Based on the facts set out above, we rule that the supply of maintenance services performed on the residential elevator in your home is a taxable supply subject to the HST on the consideration for the supply. ... Since the supply of the residential elevator in your home is not a zero-rated supply, the requirements in section 34 of Part II of Schedule VI are not met and the supply of a maintenance service performed on your elevator is subject to HST at the rate of 13% on the consideration charged by [the supplier]. ...

Taxable supplies are supplies made in the course of a commercial activity and may be taxable at the rate of 0% (zero-rated supplies), 5%, 13%, or 15% on the value of the consideration for the supply depending on the province in which the supply is made. ... The calculation excludes consideration attributable to the sale of goodwill of a business, supplies of financial services, and supplies by way of sale of capital property. ...

RULING REQUESTED You would like to know whether the trade ticket fees payable by the introducing broker to the carrying broker are consideration for the supply of an exempt financial service. RULING GIVEN Based on the facts set out above, we rule that the trade ticket fees charged by the carrying broker to the introducing broker are consideration for a taxable supply for GST/HST purposes. ...

A person (who is not a charity or public service body) is a small supplier during any particular calendar quarter and the following month if the total value of the consideration for world-wide taxable supplies (other than supplies of financial services, sales of capital property, and goodwill attributable to the sale of a business) made by the person, or an associate of the person at the beginning of the particular calendar quarter, that became due, or was paid without becoming due, in the previous four calendar quarters does not exceed $30,000. ... According to the financial information you provided for the years [yyyy-yyyy] inclusive, the total value of the consideration you received for the taxable supply of instruction of dance lessons exceeded $30,000. ...

As consideration for servicing the mortgages under the Servicing Agreement, the Seller is entitled to receive a servicing fee that is set forth in a Fee Agreement. ... The servicing fee is calculated as a percentage of the mortgages serviced by the Seller and is consideration for the services rendered by the Seller to the Purchaser. ...

Explanation Every recipient of a taxable supply made in Canada is required to pay GST/HST at the rate of 5%, 12%, 13% or 15% (depending on the place of supply) on the value of the consideration for a supply unless it is an exempt supply. ... Section 135, "Sponsorship of public service bodies", states that: "For the purposes of this Part, where a public sector body makes a) A supply of a service, or b) A supply by way of licence of the use of a copyright, trade-mark, trade-name or other similar property of the body, to a person who is the sponsor of an activity of the body for use by the person exclusively in publicizing the person's business, the supply by the body of the service or the use of the property shall be deemed not to be a supply, except where it may reasonably be regarded that the consideration for the supply is primarily for a service of advertising by means of radio or television or in a newspaper, magazine or other publication published periodically or for a prescribed service. ...

Explanation Generally, in accordance with section 165, every recipient of a taxable supply made in Canada is required to pay GST/HST on the value of the consideration for the supply, unless the supply is zero-rated (listed in Schedule VI to the ETA and subject to the GST/HST at the rate of 0%) or exempt (listed in Schedule V to the ETA and not subject to the GST/HST). ... Though product placement is a relevant consideration, it alone is not considered a determinative factor. ...