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Determining the Value of the Consideration for Transfers of New Homes-- summary under Value of the Consideration Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Subsection 1(1)- Value of the Consideration Construction of new home is part of the arrangement if the conveyance is dependent on the construction contract Construction as Part of an Arrangement Relating to a Conveyance Land is defined as including a structure to be constructed on land as part of an arrangement relating to a conveyance. ... Entering into separate agreements for the purchase of the land and the construction of a new home on it will not reduce the value of the consideration for the transaction if they are all integral to the arrangement relating to the conveyance. ... " Where the conveyance of the vacant land is dependent on the construction of the home, then the arrangement is to buy the land and the structure to be constructed; both agreements must be taken into account to determine the true value of the consideration. ...

Bulletin LTT 10-2000 "Transactions for Nominal Consideration" November 2000-- summary under Value of the Consideration Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Subsection 1(1)- Value of the Consideration Partitioning of a Co-tenancy Where a partitioning of land takes place and each or any of the "co-tenants" receives land equal in value to their original interest in the whole parcel, no tax will be payable. ...

GST/HST Memorandum 18-4 “Determining Whether a Transfer Payment is Consideration For a Supply” June 2022-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration Direct link test (paras. 7, 14) If there is a direct link between a supply made by the grantee and a transfer payment, the transfer payment is consideration for that supply, e.g., if the payment directly results in the provision of property or a service (other than for accounting or ancillary purposes) by the grantee to the grantor or a person specifically identified by the grantor (a “specified third party”). ... Where a government enters an agreement under which it gives responsibility for the delivery of a service or the administration of a program to another body but retains the legislative responsibility for delivering the program, it may be contracting out its responsibility in consideration for a transfer payment. ...

A Guide for Real Estate Practitioners- Land Transfer Tax and the Registration of Conveyances of Land in Ontario 18 February 2021-- summary under Value of the Consideration Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Subsection 1(1)- Value of the Consideration Undertaking required where there may be additional consideration or the value of consideration depends on valuation 2 UNDERTAKINGS The Land Transfer Tax undertaking An acknowledgement to provide documentation and information An acknowledgement to pay any additional Land Transfer Tax and interest determined to be payable. ... Tentative value of the consideration. Where the agreement between the parties may result in additional consideration to be given pending future events, the MOF will monitor the transaction and ensure additional tax is collected should the future conditions materialize. ... Construction contract entered into as part of the sale arrangement is added to the value of consideration 11 FREQUENTLY ASKED QUESTIONS … 22. ...

The value of the consideration is the amount of the consideration paid by the optionee to acquire the option, and not the option exercise price. ... The consideration will be determined in the same manner described in the preceding paragraph. A return must be filed and the tax paid on the consideration paid by the optionee to acquire the option. ...

GST M 300-7 "Value of Supply" under "Monetary and Non-monetary Consideration"-- summary under Subsection 153(1) Summary Under Tax Topics- Excise Tax Act- Section 153- Subsection 153(1) Where the consideration for a supply consists of money and a trade-in, the consideration for the supply will be the total of the fair market value of the trade-in plus the monetary consideration. ...

Technical Information Bulletin B-067, "Goods and Services Tax Treatment of Grants and Subsidies," 24 August 1992-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration There is a direct link between a transfer payment and a supply if the payment is directly related to the provision of a supply to the grantor, or to a third party, by the recipient of the transfer payment. If a direct link exists, the payment is consideration.... CRA also stated that if the grantor of a transfer payment (incluidng acontribution, subsidy, or similar payment) does not receive any property or service in return, then the payment is not consideration for a supply since there is no activity involved that can be considered to be a supply" ...

2 August 2017 Ruling 182285-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration Ontario electricity rebate does not reduce the consideration for the supply The Ontario Rebate for Electricity Consumers Act, 2016 provided a rebate equal to the provincial portion of HST on the electricity bills of residential, farm, small business and other eligible customers. CRA ruled that the rebate is financial assistance and does not reduce the consideration for the supply of the electricity – so that input tax credits or public service body rebate claims of the recipient are not reduced by the rebate amount. ...

("Time Tax Becomes Payable When Consideration Is Comprised Of A Forgivable Loan")-- summary under Subsection 152(1) Summary Under Tax Topics- Excise Tax Act- Section 152- Subsection 152(1) Respecting the situation where the consideration that is payable for a taxable management service is comprised of a forgivable loan which has a 5 year term (20% of principal amount being forgiven each year), CRA stated: Consistent with subsection 152(1) of the ETA, this consideration would be considered to become due according to the relevant written agreement between the management service provider and the client and when any invoices are issued. In the absence of any particular conditions on the loan advance or forgiveness of amounts under the loan and assuming that the entire amount of the loan advance is required to be advanced at the outset under the agreement, the consideration would generally be considered to be paid and to become due, and the tax would therefore generally be payable, at the time the loan advance is made, not at the time the loan is forgiven. ...

18 September 2015 Ruling 168521r-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration HST applicable to on-charges for waste diversion fees imposed on Ontario tire seller As also described in 144133, Ontario Tire Stewardship (“OTS”) was designated by Waste Diversion Ontario (“WDO”) as an industry funding organization (“IFO”) for used tires and, as such, was responsible for operating the waste diversion and recycling program in Ontario for used tires including collection, transporting and processing. ... For ETA purposes, this cost, even when separately identified as an “OTS” charge on an invoice to a tire customer, forms part of the consideration for a taxable supply of tires and is subject to GST/HST…. ... [ACo]’s tire customer) and it is not excluded from the consideration for the tire charged to the tire customer by virtue of section 154…. ...