Search - consideration

The basis for calculating the consideration for the supply made by the downstream merchant may vary. For example, the consideration may be a specific licence fee or a per transaction fee or a combination thereof. It is important to note that the method of calculating the consideration will generally not affect the characterization and tax status of the supply. ...

Theme IV: shrinking the environmental footprint, beginning with government Under Theme IV, the CRA contributed to the 2013-16 FSDS through four implementation strategies for Goal 1: Reduced greenhouse gas emissions (GHG) from operations, Goal 2: Embedded environmental considerations in Crown procurement, Goal 3: Improved sustainability in workplace operations and Goal 4: Greener services. ... Target 7.2 – Green procurement: Continue to take action to embed environmental considerations into Crown procurement Percentage of SD National Action Plan green procurement activities met In progress – The Contracting Division contacts the SD Centre of Expertise when developing RFPs and other procurement-related documents for the review and addition of environmental considerations. ... The Contracting Division contacts the SD Centre of Expertise when developing RFPs and other procurement-related documents for the review and addition of environmental considerations. ...

The determination of whether a single supply or multiple supplies are made requires consideration of the relevant facts of each case. ... Section 138 deems a supply to form part of another supply provided that they are supplied together for a single consideration. ... Whether a non-resident is carrying on business in Canada for GST/HST purposes is a question of fact requiring consideration of all relevant circumstances. ...

A fee charged for a returned cheque for insufficient funds is consideration for an exempt supply of a financial service under section1 of Part VII of Schedule V. ... Where the payment is for the use of the principal’s facilities, equipment or administrative services, the payment is consideration for a taxable supply made by the principal, and the GST/HST will generally apply. ... The amount retained by the principal is not consideration for a supply made by the principal, and as such, the GST/HST will not apply to this amount. ...

A fee charged for a returned cheque for insufficient funds is consideration for an exempt supply of a financial service under section1 of Part VII of Schedule V. ... Where the payment is for the use of the principal’s facilities, equipment or administrative services, the payment is consideration for a taxable supply made by the principal, and the GST/HST will generally apply. ... The amount retained by the principal is not consideration for a supply made by the principal, and as such, the GST/HST will not apply to this amount. ...

A fee charged for a returned cheque for insufficient funds is consideration for an exempt supply of a financial service under section1 of Part VII of Schedule V. ... Where the payment is for the use of the principal’s facilities, equipment or administrative services, the payment is consideration for a taxable supply made by the principal, and the GST/HST will generally apply. ... The amount retained by the principal is not consideration for a supply made by the principal, and as such, the GST/HST will not apply to this amount. ...

For GST/HST purposes, the amount of the security charge is included in the consideration for the supply of the air transportation service. As such, where the supply of the service, other than a zero-rated supply, is made in a participating province, the total consideration for the supply, which includes the security charge, is subject to HST at 15%. Where the supply is made in a non-participating province, the total consideration for the supply, including the security charge is subject to GST at 7% providing the supply is not zero-rated. ...

For GST/HST purposes, the amount of the ATSC is included in the consideration for the supply of the air passenger transportation service. As such, where the supply of the service, other than a zero-rated service, is made in a participating province, the total consideration for the supply, which includes the ATSC, is subject to the HST at 15%. Where the supply is made in a non-participating province, the total consideration for the supply, including the ATSC, is subject to GST at 7% provided the supply is not zero-rated. ...

Organizational structure Identification of the participants in the related party dealings and their relationship (with a brief history of and any significant changes in the relationship), including associated enterprises whose transactions directly or indirectly affect the pricing of the related party dealings A description of taxpayer's worldwide organizational structure (including an organization chart) covering all associated enterprises engaged in transactions potentially relevant to determining an arm's length price for the documented transactions Nature of the business/industry and market conditions An outline of the business including a relevant recent history of the taxpayer, the industries operated in, the general economic and legal issues affecting the business and industry, and the taxpayer's business lines The corporate business plans to the extent they give an insight into the nature and purpose of the relevant transactions between the associated enterprises A description of internal procedures and controls in place at the time of the related party dealings Analysis of the economic and legal factors that affect the pricing of taxpayer's property and services A description of the structure, intensity and dynamics of the relevant competitive environment(s) A description of intangible property potentially relevant to the pricing of the taxpayer's property or services in the controlled transactions Copies of annual reports and financial statements for the year to which the Package relates and the prior five years Information as to the functions performed, assets employed and risks assumed relevant to the transactions An explanation of capital relationships (for example, balance and source of debt and equity funding) relevant to the transactions Controlled transactions A description of the controlled transactions that identifies the property or services to which the transaction relates and any intangible rights or property attached thereto, the participants, the scope, timing, frequency of, type, and value of the controlled transactions (including all relevant related party dealings in relevant geographic markets), as well as the currency of the transactions, and the terms and conditions of the transactions and their relationship to the terms and conditions of each other transaction entered into between the participants Identification of internal data relating to the controlled transactions Copies of all relevant inter-company agreements Assumptions, strategies, policies Relevant information regarding business strategies and special circumstances at issue, for example, set-off transactions, market share strategies, distribution channel selection and management strategies that influenced the determination of transfer prices If the taxpayer pursues a market share strategy, documentation demonstrating that appropriate analysis was done prior to implementing the strategy, that the strategy is pursued only for a reasonable period, and that the costs borne by each associated enterprise are proportionate to projected benefits to such enterprise Assumptions and information regarding factors that influenced the setting of prices or the establishment of any pricing policies for the taxpayer and the related party group as a whole Cost contribution arrangements (CCA) Footnote 5 A copy of the CCA agreement that is contemporaneous with its formation (and any revision) and any other agreements relating to the application of the CCA between the CCA participants A list of the arrangement's participants, and any other associated enterprises that will benefit from the CCA The extent of the use of CCA property by associated enterprises which are not CCA participants, including the amounts of consideration paid or payable by these non-participants for use of the CCA property A description of the scope of the activities to be undertaken, including any intangible or class of intangibles in existence or intended to be developed A description of each participant's interest in the results of the CCA activities The duration of the arrangement Procedures for and consequences of a participant entering or withdrawing from the agreement (i.e., buy-in and buy-out payments) and for the modification or termination of the agreement The total amount of contributions incurred pursuant to the arrangement The contributions borne by each participant and the form and value of each participant's initial contributions (including research) with a description of how the value of initial and ongoing contributions is determined and how accounting principles are applied A description of the method used to determine each participant's share of the contributions including projections used to estimate benefits, any rationale and assumptions underlying the projections, and an explanation of why that method was selected The consistent accounting method used to determine the contributions and benefits (including the method used to translate foreign currencies), and to the extent that the method materially differs from accounting principles accepted in the relevant PATA member's country, an explanation of the material differences Identification of each participant's expected benefits to be derived from the CCA, the extent of the benefits expected, and the formula and projections used for allocating or sharing the expected benefits, and the rationale and assumptions underlying the expected benefits Where material differences arise between projected benefits and actual benefits realized, the assumptions made to project future benefits need to be amended for future years, and the revised assumptions documented Procedures governing balancing payments, e.g. where payments are required to reflect differences between projected benefits and actual benefits realized Comparability, functional and risk analysis Description of the comparables including, for tangible property, its physical features, quality, availability; for services, the nature and extent of the services; and for intangible property, the form of the transaction, the type of intangible, the rights to use the intangible that are assigned, and the anticipated benefits from its use Documentation to support material factors that could affect prices or profits in arm's length dealings For the taxpayer and the comparable, identify the factors taken into account by the taxpayer to evaluate comparability, including the characteristics of the property or service transferred, the functions performed (and the significance of those functions in terms of their frequency, nature and value to the respective parties), the assets employed (taking into consideration their age, market value, location, etc.), the risks assumed (including risks such as market risk, financial risk, and credit risk), the terms and conditions of the contract, the business strategies pursued, the economic circumstances (for example, the geographic location, market size, competitive environment, availability of substitute goods and services, levels of supply and demand, nature and extent of government regulations, and costs of production, etc.), and any other special circumstances Criteria used in the selection of comparables including database screens and economic considerations Identification of any internal comparables Adjustments (and reasons for those adjustments) made to the comparables Aggregation analysis (grouping of transactions for comparability) Supporting transfer pricing methodology or methodologies used, if any If a range is used, documentation supporting the establishment of the range Extension of the analysis over a number of years with reasons for the years chosen, where relevant Selection of the transfer pricing method Description of the method selected and the reasons why it was selected, including, for example, economic analysis and projections relied upon Description of the data and methods considered and the analysis performed to determine the transfer pricing and an explanation of why alternate methods considered were not selected Application of the transfer pricing method Documentation of assumptions and judgments made in the course of determining an arm's length outcome (refer to the comparability, functional and risk analysis section above) Documentation of all calculations made in applying the selected method, and of any adjustment factors, in respect of both the taxpayer and the comparable Appropriate updates of prior year documentation relied upon in the current year to reflect adjustments for any material changes in the relevant facts and circumstances Index to documents Background documents Documents that provide the foundation for or otherwise support or were referred to in developing the transfer pricing analysis General index of documents and a description of the record-keeping system used for cataloging and assessing those documents (required in the United States and encouraged, but not required, by other PATA members). ...