Search - consideration

" (item # 2) and "... partial consideration..." (item # 3). ... Apportionment of Tax Subsection 153(2) applies where consideration is paid for a supply and other consideration is paid for one or more other supplies, and the consideration for one of the supplies exceeds the amount that would be reasonable if the other supply were not made. ... In the subject case, we have no evidence that there has been an unreasonable apportionment of the consideration between the supplies. ...

A further indication that the research, teaching, and administrative services are separate and distinct supplies is the manner in which the independent contractors receive consideration from XXXXX for these supplies. ... The consideration payable by the hospital in exchange for these supplies consists of the use of physical space, clerical and administrative staff, medical residents, and equipment. Where the consideration for a supply is other than money, subsection 153(1) of the ETA deems the value of that consideration to be equal to the fair market value of the consideration at the time the supply was made. ...

These beer bottles are ordinarily acquired by consumers, are ordinarily acquired by consumers when filled and sealed, and are ordinarily supplied empty by consumers for consideration. ... The rules of the simplified method apply to all registrants except those who are specifically excluded in subsection 226(5) of the ETA: "Subsections (3) and (4) do not apply to a registrant in respect of a supply of a returnable container of a particular class made by or to the registrant where, at the time tax in respect of the supply becomes payable, the usual practice of the registrant is (a) to charge consideration for supplies of filled and sealed containers of that class that exceeds the consideration the registrant pays to registrants for supplies of filled and sealed containers of that class; (b) to charge consideration for supplies of empty containers of that class made to other registrants that exceeds the consideration the registrant pays or would pay to other registrants for supplies of empty containers of that class; (c) to pay consideration for supplies of empty containers of that class received from persons who are not registrants that is less than the total of the consideration that the registrant charges for supplies of empty containers of that class and tax calculated on that consideration; (d) to import filled and sealed containers of that class; (e) to engage other persons to fill and seal containers of that class for the registrant; or (f) to manufacture, produce or fill and seal returnable containers of any class. ... This is accomplished by the deeming provisions of subsection 226(2): "For the purposes of this section, where a person supplies a beverage in a returnable container, (a) the provision of the container shall be deemed to be a supply separate from, and not incidental to, the provision of the beverage; (b) section 137 does not apply to deem the container to form part of the beverage; and (c) the consideration for the supply of the container shall be deemed to be equal to that part of the total consideration for the beverage and the container that is reasonably attributable to the container. ...

The consideration paid or payable must be directly linked to a supply of a health care service that is in fact rendered by a physician to a particular individual. ... As consideration for a supply of “property”, the hospital on-call fee is not consideration paid or payable for a supply of a service for GST/HST purposes. ... Accordingly, the hospital on-call fee paid by a hospital to a physician is consideration for a taxable supply. ...

In a situation where subsection 153(4) does not apply, the trade-in does not reduce the consideration being paid for the other property. ... If it is a taxable supply that is not zero-rated, the supplier (if a registrant) must collect tax on the value of the consideration. ... This is not only evident from contract principles, but in fact is expressly spelled out in subsection 153(1) of the ETA, which provides that the consideration for a supply is equal to the amount expressed in money plus, where the consideration or a part is other than money, the fair market value of the non-monetary consideration. ...

Section 13 of Part III of Schedule V states that a student may receive for a single consideration only the right to receive at a restaurant or cafeteria at the university or college not less than 10 meals weekly throughout the period. ... Taking into consideration the requirements of section 13 of Part III of Schedule V, we will respond to each of your questions separately: 1. ... The CRA considers "top-ups" or the addition of funds to a qualifying meal plan to be additional consideration for the same supply. ...

. * [The Corporation] is liable to pay the consideration for the supplies made by [A Co] and [B Co] and is the recipient of those supplies. ... Application of TIB B-32 Under TIB B-32, where pension related expenses incurred by the employer (i.e., the person liable to pay the consideration under the agreement for the supply) have been paid for out of pension plan trust assets, the payment by the trust is generally treated as consideration for a supply made by the employer to the trust where: * the plan trust pays the third party supplier directly, * the employer invoiced the plan trust for the costs of the inputs, and/or * the plan trust reimburses the employer. ... In the present case, since the pension entity paid [A Co] and [B Co] directly for the investment management services, we would consider [the Corporation] to have made a taxable supply of the services to the pension entity for consideration equal to the invoice amounts. ...

Subsection 168(1) provides that “tax under this Division (Division II) in respect of a taxable supply is payable by the recipient on the earlier of the day the consideration for the supply is paid and the day the consideration for the supply becomes due”. Subsection 152(1) indicates when consideration is due. It provides that “(…) the consideration, or a part thereof, for a taxable supply shall be deemed to become due on the earliest of a) the earlier of the day the supplier first issues an invoice in respect of the supply for that consideration or part and the date of that invoice, b) the day the supplier would have, but for an undue delay, issued an invoice in respect of the supply for that consideration or part, and c) the day the recipient is required to pay that consideration or part to the supplier pursuant to an agreement in writing.” ... Therefore, even though there is no equivalent to subsection 169(4) or to the Regulations previously mentioned, there is a reference to tax paid or payable and by inference, to the moment the consideration is due. ...

Determining when a brokerage performs its services Generally, section 43 of the New Harmonized Value-Added Tax System Regulations (the Regulations) provides that the HST at 13% applies to any consideration that become due or is paid without having become due, on or after May 1, 2010, for a taxable supply of a service made in [Participating Province X] to the extent that the consideration relates to the portion of the service performed on or after July 1, 2010. However, if all or substantially all (i.e., 90% or more) of the service is performed before July 2010, only the GST at 5% is payable on the consideration for the taxable supply of the service. ... The commission is the consideration for the taxable supply of the listing brokerage's service to the seller. ...

In other words, when a Card bearer takes a discount on a meal or beverage, Co A/ Co B is viewed as making a taxable supply of meals and beverages to *** for which it subsequently receives monetary consideration. ... Instead, they fall within subsection 181(4), which deems the value of the consideration for the supply to be the amount, if any, by which the value of the consideration for the supply as otherwise determined exceeds the exchange value of the coupon (i.e., the GST/HST applies to the price net of the coupon value). Accordingly, where a coupon confers a free meal or beverage to the user, subsection 181(4) essentially deems the value of consideration for the supply to be zero, and no tax will be payable on the supply. ...