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GST/HST Interpretation

12 April 2000 GST/HST Interpretation 8394/HQR0002000 - Sale-leaseback Arrangements - Entitlements to ITCs

The Purchaser/lessor is a wholly-owned subsidiary of the Registrant, whose business is the holding of properties to be leased, for consideration, to the Registrant. ... These subsections require that a person determine whether it acquired or imported property or services, for the purpose of an endeavour that involves the making of supplies for consideration. ... The information you provided on behalf of your client is that the Purchaser/lessor's business consists of the holding of properties to be leased, for consideration, to the Registrant and that the Purchaser/lessor is charging GST on the rental fee. ...
GST/HST Interpretation

27 July 2009 GST/HST Interpretation 110373 - Purchase and Sale of Discounted Gift Cards

When given as consideration for a supply at the restaurant, the gift card is considered to be money. ... The "gift card" must come within the meaning of the term "gift certificate" as described in GST/HST Policy Statement P-202, Gift Certificates: it has a stated monetary value; it can be redeemed for the purchase of property or a service from a particular supplier; consideration has been given for it; and it has no intrinsic value. ... When a gift certificate is given as consideration by the consumer, it is treated as money. ...
GST/HST Interpretation

24 September 2004 GST/HST Interpretation 45519 - Application of GST to Digital Images and Graphic Designs

No GST/HST applies to the consideration charged because of section 179(3) of the Excise Tax Act ("the Act"). ... Interpretation Requested Whether the registrant in the circumstances described above is entitled to an ITC pursuant to subsection 169(2) of the Act for the tax paid on the importation of the goods where no consideration is charged to the non-resident supplier for the warehousing service. ... Based on the information provided, the registrant who is supplying a commercial service to the non-resident supplier by storing the goods is entitled to an ITC pursuant to subsection 169(2) of the Act for the tax paid on the importation of the goods, regardless of whether the registrant charges consideration for the supply of the commercial service. ...
GST/HST Interpretation

18 August 2004 GST/HST Interpretation 53883 - Temporary Importation of Amusement Ride

Therefore, no tax applies to the consideration paid by the City to XXXXX for this service. ... Therefore, no tax applies to the consideration paid by the individual users for the service, namely the fares collected by XXXXX on the City's behalf. ... Bonnah Chron file XXXXX Legislative References: subsection 259(3), section 24 of Part VI of Schedule V NCS Subject Code(s): 11890-7, 11894-13-5 2004/08/25 — RITS 53938 — Definition of "Consideration" for GST/HST Purposes ...
GST/HST Interpretation

2 November 1994 GST/HST Interpretation 11610-7[1] - Application of Containers Policy to Boomgear

Instead the amount payable on the supply of the boomgear to the supplier is to be treated as consideration for the supply and tax calculated on the amount is payable at the time the consideration is payable. ... In the absence of other information we have assumed that the amount is not a deposit but, rather, is consideration for the supply of the boomgear. ...
GST/HST Interpretation

2 November 1994 GST/HST Interpretation 11610-7[2] - Application of Containers Policy to Boomgear

Instead the amount payable on the supply of the boomgear to the supplier is to be treated as consideration for the supply and tax calculated on the amount is payable at the time the consideration is payable. ... In the absence of other information we have assumed that the amount is not a deposit but, rather, is consideration for the supply of the boomgear. ...
GST/HST Interpretation

5 December 1996 GST/HST Interpretation 11930 - GST Status of Membership Fees in a Public Sector Body

Pursuant to paragraph 17(d), the right to receive or acquire property or services supplied to the member for consideration that is not part of the consideration for the membership and that is equal to the fair market value of the property or services at the time the supply is made is an acceptable benefit. ... The second condition is met if the premiums paid by the members are the actual premiums established by the insurer and the members receive the service for consideration equal to its fair market value (taking any subsequent refunds of premiums into account). ...
GST/HST Interpretation

19 November 1996 GST/HST Interpretation 11750-5-2 - Transfer of Remainder Interest in Farmland With Life Interest Retained

If yes, what is the value of the consideration? 2. Is there a supply of a life interest in the farm from the son to the farmer, for GST purposes? If yes, what is the value of the consideration? GST Treatment 1. Supply of remainder interest Paragraph 123(1)(a) of the Excise Tax Act ("the Act") states that "real property" includes "every estate or interest in real property, whether legal or equitable". ... Under section 155 of the Act, the value of the consideration for such a non-arm's length transaction is deemed to be the fair market value of the remainder interest in the farm. 2. ...
GST/HST Interpretation

1 July 1996 GST/HST Interpretation 11585-32[9] - Multi-employer Pension Plans

In your view, "the fact that the administrator provides these services for nil consideration does not mean that such services are not in the course of the administrator's commercial activities". ... In the alternative, a portion of the contribution paid by the employers can be viewed as consideration for the supply of the Employer Expenses made by the administrator; and the employers would be allowed to claim ITC's based on their prorated shares of the Employer Expenses. ... In a MEPP, if the plan administrator does not acquire the "Employer Expenses" for use in providing a taxable supply of the administrative services to another person or does not charge a consideration for the supply, the administrator cannot be said to have acquired those Employer Expenses for use "in the course of its commercial activities". ...
GST/HST Interpretation

10 April 1996 GST/HST Interpretation 11640-2 - Application of the GST to the Supply of Intangible Personal Property

In other words, a royalty is not a right, but is consideration for a supply. ... In consideration of this supply, XXXXX pays to XXXXX a royalty, based on quarterly sales of pressure vessels. ... XXXXX stated that the royalty payment received by XXXXX, in consideration of the supply of a right to XXXXX to use the patent of the pressure vessels and the consulting services supplied by XXXXX were subject to the GST. ...

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