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Explanation Generally, in accordance with section 165 of the ETA, every recipient of a taxable supply made in Canada is required to pay GST/HST on the value of the consideration for the supply, unless the supply is zero-rated (listed in Schedule VI to the ETA and subject to the GST/HST at the rate of 0%) or exempt (listed in Schedule V to the ETA and not subject to the GST/HST). ... Though product placement is a relevant consideration, it alone is not considered a determinative factor. ...

Ruling Given Based on the facts set out above, we rule that the amount charged for the rental of the Site is consideration for a supply of land that is exempt of the GST/HST under subparagraph 7(a)(i) of Part I of Schedule V to the ETA. ... Whether a particular unit has the same permanent residential characteristics as a house such that it is considered to be a "residential unit", is affixed to the land, and is used as a place of residence for individuals is determined on a case-by-case basis taking into consideration the facts and circumstances of the particular case. ...

EXPLANATION As indicated in your incoming letter, you would like to receive an explanation of the primary factors that the Canada Revenue Agency takes into consideration in determining the nature of a supply. ... Each factor must be given equal consideration and a determination must be made based on the overall facts relating to the transaction in question. ...

In the present case, the expenses incurred by [A Co] (the person liable to pay the consideration under the agreement for the supply) with respect to services related to the administration of the Pension Plan relate to property or services acquired for consumption, use or supply in the course of [A Co]’s activities. ... As with the investment management services of [C Co], where expenses incurred by [A Co] have been paid from the Pension Fund, we would consider [A Co] to have made a taxable supply of services for consideration equal to the invoice amounts. ...

RULING GIVEN Based on the facts set out above, we rule that that the funding provided by the Funder to […][you] is a grant and not consideration for a supply and therefore, not subject to the GST/HST. ... In accordance with the guidelines set out in the TIB-067 Goods and Services Tax Treatment of Grants and Subsidies, in general, transfer payments made for a public purpose or for charitable purposes will not be consideration for a supply under the ETA unless there is a “direct link” between the payment and a provision of goods and services made to the grantor of the funding or a specified third party. ...

We further rule that the annual amount payable to the Association by a member for site licence fees and the maintenance of common amenities is consideration for the exempt supply referred to above. ... The amount payable upon entering the Agreement and the annual amounts payable to the Association by a member for site licence fees and the maintenance of common amenities is consideration for the exempt supply referred to above. ...

Where a person acquires or imports property or a service or brings it into a participating province for consumption or use in the course of its endeavour, to the extent that it does so for the purpose of making taxable supplies for consideration, subsection 141.01(2) deems the person to have acquired, imported or brought in the property or service for consumption or use in the course of its commercial activities. To the extent that a person acquires, imports or brings in property or a service for the purpose of making supplies that are not taxable supplies for consideration, or for a purpose other than making supplies in the course of its endeavour, subsection 141.01(2) deems the person to have acquired, imported or brought in the property or service for consumption or use otherwise than in the course of its commercial activities. ...

What did the supplier provide for the consideration received? 4. Is the recipient made aware of the elements (in detail) that are part of the package? ... ADDITIONAL INFORMATION Where a single supply of delivered goods is made and there is a separate charge for the delivery service, that deliver fee is considered to be consideration for the single supply of the specific good which it is shown as relating to. ...

. […] RULING REQUESTED You would like to know whether: 1) the supply of […] services made by [CanCo] to the Operator is zero-rated pursuant to paragraph 2(a) of Part V of Schedule VI; and, 2) the tax already paid on consideration for that supply may be recovered by the Operator. RULING GIVEN Based on the facts set out above, we rule that: 1) The supply of […] services made by [CanCo] to the Operator is zero-rated under paragraph 2(a) of Part V of Schedule VI; and, 2) The tax paid on consideration for the zero-rated supply of […] services may be recovered by the Operator in the manner described below. ...

As per section 165, GST/HST is calculated on the value of the consideration for the supply. It is a question of fact whether tax has been added to the value of consideration or if the GST/HST is extra. ...