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A distribution platform operator in respect of a supply of property or a service made through a specified distribution platform is a person other than the supplier or an excluded operator who: controls or sets the essential elements of the transaction between the supplier and the recipient, or if that circumstance does not apply to any person, is involved, directly or through arrangements with third parties, in collecting, receiving or charging the consideration for the supply and transmitting all or part of the consideration to the supplier. In relation to a supply of property or a service, an excluded operator is a person who: does not set, directly or indirectly, any of the terms and conditions under which the supply is made, is not involved, directly or indirectly, in authorizing the charge to the recipient of the supply in respect of the payment of the consideration for the supply, and is not involved, directly or indirectly, in the ordering or delivery of the property or in the ordering or rendering of the service; or solely provides for the listing or advertising of the property or service or for the redirecting or transferring to a digital platform on which the property or service is offered; or is solely a payment processor. ... Specified supplies include, but are not limited to: online subscription-based video or music streaming mobile apps E-books online video gaming traditional services such as legal and accounting services There are several types of supplies that are not considered to be specified supplies, including: supplies that may not be consumed or used in Canada, supplies that relate to tangible personal property or real property that is situated outside Canada, and services that are supplied to a person in connection with a supply of short-term accommodation made to the person, and the consideration for which represents a booking fee, administration fee or other similar charge. ...

In exercising discretion, the Minister is guided by principles of procedural fairness which require decisions to be made in good faith, in a manner that promotes the objects of the relevant legislation, without discriminating between applicants on the basis of irrelevant considerations. This memorandum provides some general guidelines on some of the relevant considerations in the exercise of this discretion. ... If it is discovered during the course of the review that the registrant had previously made an application, the CRA may refuse to give the second application further consideration under the VDP. 39. ...

Audits and evaluations are identified using a risk-based approach that includes consideration of Agency-wide risks identified in the CRA Corporate Risk Inventory (CRI) and through CAEB's own analysis of CRA risks. CAEB also takes into consideration the CRA Corporate Business Plan (CBP), the Treasury Board Secretariat (TBS) Management Accountability Framework (MAF) and the Board of Management Oversight Framework (BoMOF). ... The feasibility of including the areas ofexamination for this audit in the Cyclical IT Security Audit is also beingtaken into consideration during the deferral period. ...

The consideration for the transfer is preferred shares retractable at the option of the parent for an amount equal to the fair market value of the shares of the operating company transferred. ... Similar considerations would apply to other types of estate freezes involving a transfer of property by a parent to a corporation. ... The taxpayer sells this property to an arm's length taxable Canadian corporation in consideration for redeemable shares having a redemption amount equal to the fair market value of the property sold. ...

In addition, each separate supply of those services would be deemed to be made on the first day of the reporting period of the general partner for consideration that becomes due on the last day of the reporting period equal to the FMV of the services rendered under the agreement during the reporting period. ... The monthly payments on which GST/HST was charged are deemed to be consideration for a taxable supply of the prior services. ... The portion of the September 1, 2017 payment attributable to the prior services on which GST/HST was charged is deemed to be consideration for a taxable supply of those services. ...

Customs determines that this royalty should be taken into consideration when arriving at the value for duty, and the full value of $250,000 is reflected in the transaction value. ... It is possible that price reductions after importation would be taken into consideration for income tax purposes but not for customs purposes. ... If section 48 of the Customs Act (transaction value of the goods) cannot be applied, consideration must then be given to the method of valuation set out in section 49. ...

With respect to the five preceding questions, consideration must be given to the technology base or level and the business environment of the individual company. ... A technological uncertainty may thus arise that is imposed by economic considerations. ... It is important to realize that consideration is given to the exclusions only after it has been determined that there is SR&ED. ...

Therefore, consideration must be given to statutory provisions regarding agency before applying the legal principles examined below. ... Since the supply made by PMC is a taxable supply (other than zero-rated), these consideration, including that part taken from the gross rental revenues, is subject to tax. ... The separate permit charge billed by Moving to Pat Dawson constitutes a part of the consideration for the moving service supplied to Pat Dawson. ...

However, section 1.2 of Part II of Schedule V does not apply to supplies of property or services where the consideration for the supply is payable or reimbursed by a provincial health care plan. ... The total of the consideration for the check-up is paid by a provincial health care plan and is exempt under section 9 of Part II of Schedule V. ... Rationale In this case, the consideration for the supply of the medical examination is paid for by the provincial health care plan and the supply is exempt under section 9 of Part II of Schedule V. ...

However, since there is typically no identifiable recipient of this taxable supply, and no identifiable liability for payment in respect of the supply, there is generally no consideration for such a supply and therefore no obligation to collect and remit the GST/HST. ... For example, in order for a person to be eligible to claim an ITC, a person must generally be making taxable supplies for consideration in the course of the endeavour of the person. Subsection 141.01(4) can apply in certain circumstances where acquisitions relate to making taxable supplies for no consideration and it can reasonably be regarded that the supply for no consideration is made for the purpose of facilitating, furthering or promoting an endeavour of any person. ...