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1 May 1998 GST/HST Interpretation 1998-05-01[2]- XXXXX Energy Performance Contracts Additional Consideration for the Supply Subsequent Reductions in Consideration Unedited CRA Tags ETA 232(1), 232(2)  XXXXX Douglas Wood A/Rulings Officer General Operations Unit General Operations and Border Issues Division Subject: XXXXX Energy Performance Contracts Additional Consideration for the Supply Subsequent Reductions in Consideration This memorandum is in response to your e-mail of September 4, 1997, and your subsequent telephone calls, where you requested our views on amounts refunded or credited by XXXXX to its customers, as part of energy performance contracts. ... The amount subsequently refunded or credited to the customer would be regarded as a reduction in consideration, to which subsection 232(2) of the ETA would apply.   ... Consequently, a refund or credit to the customer, as provided for under paragraph 23.6 of the XXXXX, would be regarded as a subsequent reduction in consideration, under subsection 232(2) of the ETA. ...

The "value of the consideration" is defined under subsection 153(1) as "(a) where the consideration or that part (of the consideration) is expressed in money, the amount of the money; and (b) where the consideration or that part is other than money, the fair market value of the consideration or that part at the time the supply was made. ... The "value of the consideration" is defined under subsection 153(1) as "(a) where the consideration or that part (of the consideration) is expressed in money, the amount of the money; and (b) where the consideration or that part is other than money, the fair market value of the consideration or that part at the time the supply was made. ... Host Org B pays no other consideration to Owner A for the use of the venue. ...

Answer For GST purposes, a rebate paid to a XXXXX under the XXXXX does not reduce the value of the consideration for the supply. ... Section 123 of the ETA provides that "consideration" includes any amount that is payable for a supply by operation of law. ... The value of the consideration for the XXXXX purchased by XXXXX includes the market price, the XXXXX[.] ...

Under subsection 232(2) of the ETA, where a vendor has charged to, or collected from XXXXX tax under Division II, calculated on the consideration, or a part thereof for a supply, and for any reason, the consideration or part is subsequently reduced (i.e., subsequent increase to the "% in lieu"), the vendor may, in or within four years after the end of the reporting period of the vendor, in which the consideration was so reduced, where tax calculated on the consideration or part was charged but not collected, adjust the amount of tax charged by subtracting the portion of the tax that was calculated on the amount by which the consideration, or part was so reduced. The vendor may, in or within four years after the end of the reporting period of the vendor in which the consideration was so reduced, where the tax calculated on the consideration or part was collected, refund or credit to XXXXX the portion of the tax that was calculated on the amount by which the consideration or part was so reduced. ... This amount would be regarded as additional consideration for the supply, and would be subject to the general imposition rules under the ETA. ...

Specifically, is the XXXXX administrative service supplied for nominal consideration? ... Our Comments: The term "nominal consideration" is not defined in the Act. ... It is our view that whether or not an amount charged for the making of a supply is "nominal consideration" can only be determined with reference to the value of the supply for which the consideration is being charged. ...

Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 XXXXX XXXXX XXXXX XXXXX XXXXX Case Number: 104557 XXXXX June 2, 2008 Subject: GST/HST INTERPRETATION Rate of tax on credit of consideration Dear XXXXX: Thank you for your XXXXX concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to consideration credited by a supplier to XXXXX All legislative references are to the Excise Tax Act (ETA) and the regulations thereunder, unless otherwise specified. ... The supplier charged GST at the rate of 6% on the consideration for the services included in the XXXXX invoice. In the XXXXX invoice, the supplier credited GST at the rate of 5% on the consideration for the unused services previously invoiced in XXXXX. ...

Required provincial legislation has been introduced but is still under consideration by the Legislative Assembly of British Columbia. ... In accordance with the general GST/HST rules iFootnote 1, any consideration or part of the consideration under the contract, other than an amount that is a holdback, that has not been paid or become due on or before July 31, 2010, would be considered to become payable on that date. ... The contractor, if a GST/HST registrant, is required to collect the GST/HST on the full value of the consideration for the supply. ...

14 January 2015 GST/HST Interpretation 165076- Changes to the GST/HST Election for Nil Consideration Unedited CRA Tags ETA 156; Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 165076 Dear [Client]: Subject: GST/HST INTERPRETATION Changes to the GST/HST Election for Nil Consideration Thank you for the letter […], concerning amendments to the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) “Election for Nil Consideration” effective January 1, 2015. ... Effective January 1, 2015, an election or revocation of an election must be made by completing and filing Form RC4616, Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes. ...

29 January 2015 GST/HST Interpretation 167061- GST/HST Election for Nil Consideration Unedited CRA Tags ETA 156; Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 167061 Dear [Client]: Subject: GST/HST INTERPRETATION GST/HST Election for Nil Consideration This is in reply to the letter of […], concerning the amendments to section 156 of the Excise Tax Act (the ETA) and the election Form RC4616: Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes (formerly Form GST25). ... INTERPRETATION REQUESTED [You asked a number of operational questions about Form RC4616 and the amendments to section 156.] […] INTERPRETATION GIVEN At any time after 2014, where a person that satisfies the requirements set out in section 156 for being a specified member of a qualifying group files an election made jointly with another specified member of the group, every taxable supply, with certain exceptions, made between those two members at a time when the election is in effect is deemed to have been made for no consideration. ...

6 June 2003 GST/HST Interpretation 43271- Section 156 Election for Nil Consideration Unedited CRA Tags ETA 128; ETA 123(1) qualifying subsidiary Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 XXXXX XXXXX XXXXX XXXXX Case Number: 43271 XXXXX June 6, 2003 Subject: GST/HST INTERPRETATION Section 156 Election for Nil Consideration Dear XXXXX: Thank you for your letter XXXXX XXXXX with attachments XXXXX. ...