Search - consideration

The determination of the person who is entitled to an ITC for the tax can be affected by the application of various provisions of the ETA including section 178.8, and requires consideration of all relevant facts. ... A determination of the particular provision under which a supply of a freight transportation service is zero-rated requires consideration of all the relevant facts and agreements. ...

As consideration for the rights granted under the Franchise Agreement, the agreement requires an initial franchise fee of $[…] and royalty fees of […]% of gross sales. ... Consideration for this property and service is payable as [#] installments of $[…] plus any balance due. ...

Taxable supplies (including zero-rated) are made in the course of a commercial activity and are subject to the GST/HST on the value of consideration. ... However, section 5.1 of Part V.1 of Schedule V provides another potential exempting provision which stipulates that a supply may be exempt if the consideration for which the property is sold does not exceed its direct cost. ...

Under the […]([…][Program]), the Supplier sold to the Investor [#] [Program] packages on [mm/dd/yyyy], and charged GST on the total consideration. ... As such, the Investor would be required to register for the GST/HST (unless considered to be a small supplier) and charge GST/HST on the consideration for the supply of the services (i.e., the transaction fees generated from the POS terminals). ...

The determination of the person who is entitled to an ITC under subsection 169(1) for the tax on imported goods can be affected by the application of various provisions, including sections 178.8 and 180 which are explained below, and requires consideration of all relevant facts. ... The determination of whether a non-resident person is considered to be carrying on business in Canada for GST/HST is a question of fact requiring consideration of all relevant facts. ...

The relevant terms of the Contract are as follows: • XXXXX of the Contract XXXXX, states that for consideration of XXXXX, the Guarantor agrees to issue the Completion Guarantee to XXXXX (the Financier), in form mutually approved by the Guarantor and the Financier, and upon the terms and conditions set forth in XXXXX to the Contract, XXXXX. ... Consequently, the supply to the XXXXX of agreeing to provide the Completion Guarantee to the Financier, for which the Guarantor is paid consideration of XXXXX is not exempt under section 1 of Part VII of Schedule V. ...

An amount paid or payable by a direct seller or an ISC of the direct seller to an ISC of the direct seller because of the volume of purchases or sales of exclusive products of the direct seller or of sales aids and not as consideration for a supply of such a product or sales aid, is deemed not to be consideration for a supply. ...

Intercompany Transactions: Please note that with respect to the intercompany transactions, when a supply of property or a service is made between persons not dealing with each other at arm's length for consideration less than the fair market value of the property or service at the time the supply is made, and the recipient of the supply is not a registrant who is acquiring the property or service for consumption, use or supply exclusively in the course of commercial activities of the recipient, the value of the consideration is deemed to be equal to the fair market value of the property or service at that time for GST/HST purposes. ...

Pursuant to subsection 123(1), "improvement", in respect of property of a person, means any property or service supplied to, or goods imported by, the person for the purpose of improving the property, to the extent that the consideration paid or payable by the person for the property or service or the value of the goods is, or would be if the person were a taxpayer under the Income Tax Act, included in determining the cost or, in the case of property that is capital property of the person, the adjusted cost base to the person of the property for the purposes of the Income Tax Act. ... A rebate shall not be paid to a person under section 257 in respect of a taxable sale of real property made by the person unless the person files an application for the rebate (i.e., the GST189) within two years after the day the consideration for the supply of the real property became due or was paid without having become due. ...

Explanation Ruling #1 Since the Church's requirement to pay the Latecomer fees (XXXXX) is set out in the First and Second Agreements as a condition precedent for the issuance of a building permit or development permit, the Latecomer fees are regarded as consideration for the supply of a permit. ... However, the Church is entitled to claim a rebate under section 261 for the tax paid in error to the City in respect of the Latecomer fees which are consideration for an exempt supply. ...