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Old website (cra-arc.gc.ca)

Meaning of the Phrase a Particular Class or Kind as Found in subsection 153(3) of the Act

The value of the consideration for the supply made by one person is the fair market value of property received from the other person. ... Under this subsection, where: a) the consideration or a part of the consideration for a supply of property of a particular class or kind is property of that class or kind, b) both the supplier and the recipient are registrants, and c) the property is acquired by the recipient and the consideration or that part thereof is acquired by the supplier as inventory for use exclusively in commercial activities of the recipient or supplier, as the case may be, the value of the consideration or that part thereof shall be deemed to be nil. ... Hence, the value of consideration for the supply by each of Co. A and Co. ...
Scraped CRA Website

P-221 Meaning of the phrase "a particular class or kind" as found in subsection 153(3) of the Act

The value of the consideration for the supply made by one person is the fair market value of property received from the other person. ... Under this subsection, where: a) the consideration or a part of the consideration for a supply of property of a particular class or kind is property of that class or kind, b) both the supplier and the recipient are registrants, and c) the property is acquired by the recipient and the consideration or that part thereof is acquired by the supplier as inventory for use exclusively in commercial activities of the recipient or supplier, as the case may be, the value of the consideration or that part thereof shall be deemed to be nil. ... Hence, the value of consideration for the supply by each of Co. A and Co. ...
Current CRA website

P-221 Meaning of the phrase "a particular class or kind" as found in subsection 153(3) of the Act

The value of the consideration for the supply made by one person is the fair market value of property received from the other person. ... Under this subsection, where: a) the consideration or a part of the consideration for a supply of property of a particular class or kind is property of that class or kind, b) both the supplier and the recipient are registrants, and c) the property is acquired by the recipient and the consideration or that part thereof is acquired by the supplier as inventory for use exclusively in commercial activities of the recipient or supplier, as the case may be, the value of the consideration or that part thereof shall be deemed to be nil. ... Hence, the value of consideration for the supply by each of Co. A and Co. ...
GST/HST Interpretation

22 June 2010 GST/HST Interpretation 97525 - Gift Certificates

However, the amount of 10% of the redemption value of the gift certificate retained by the corporation would be viewed as consideration for a taxable supply provided to Company B of distributing Company B's gift certificate; the amount retained would be consideration for the taxable supply provided by the corporation to Company B and subject to GST/HST as applicable. ... Explanation Section 181.2 provides for the treatment of gift certificates and, in part, reads:...the issuance or sale of a gift certificate for consideration shall be deemed not to be a supply and, when given as consideration for a supply of property or a service, the gift certificate shall be deemed to be money. ... As long as the gift certificate is issued or sold for consideration, the sale of the gift certificate at a discount does not attract the GST/HST. ...
GST/HST Interpretation

6 July 2011 GST/HST Interpretation 131657 - Renovations to [...] [a residential complex]

Your view is that amounts paid by the Tenant to the Landlord in accordance with the MOU are either consideration for the exempt supply made by the Landlord to the Tenant under the Lease Agreement or are not consideration for a supply and therefore not subject to the GST/HST. ... Accordingly, we are unable to conclude that amounts paid by the Tenant in accordance with the MOU are consideration for the supply made by the Landlord under the Lease Agreement. ... If the amount paid by the Tenant is not consideration for the supply of the Complex made by the Landlord under the Lease Agreement, amounts paid by the Tenant to the Landlord in accordance with the MOU would generally be viewed as consideration for a supply of a service provided by the Landlord to the Tenant. ...
GST/HST Interpretation

27 April 1998 GST/HST Interpretation HQR0000949 - Tax Status of Cash Sponsorships of the

Ruling Requested Are the sponsorship payments received by XXXXX for the XXXXX conference consideration for taxable supplies? ... Subsection 153(1) of the ETA provides that the "value of consideration" for a supply is deemed to be: "(a) where the consideration... is expressed in money, the amount of the money; and  (b) where the consideration... is other than money, the fair market value of the consideration... at the time the supply was made. ... As noted under the ruling, we would generally accept the fair market value of the supply as a reasonable basis for the value of consideration. ...
GST/HST Ruling

14 September 1999 GST/HST Ruling HQR0001829 - Application of the GST/HST to a Grocery Rewards Program

In such a situation the coupon would be used as partial consideration against the multiple supplies made by XXXXX which of course include non zero-rated goods. ... The amount of the discount provided by the XXXXX points will reduce the value of the consideration for each of the goods purchased, further to subsection 181(4). ... The amount of the discount would need to be prorated among each of the items purchased based upon the value of the consideration for each item. ...
GST/HST Interpretation

31 March 2000 GST/HST Interpretation 7308/HQR0000914 - Exchange of Land

These two supplies constitute consideration for each other. Subsection 153(1) of the Act provides: Subject to this Division, the value of the consideration, or any part thereof, for a supply shall, for the purposes of this Part, be deemed to be equal to (a) where the consideration or that part 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 for the supply of Lot B is the FMV of Lot A at the time when Lot B is supplied. ... As previously mentioned, the value of consideration for Lot B is the FMV of Lot A at the time of the sale of Lot B. ...
GST/HST Interpretation

30 May 2024 GST/HST Interpretation 246958 - Zero-rated Supplies of Financial Services and Eligibility for Input Tax Credits

The consideration for this supply was the Partnership Interest the Investor received in return. ... Even assuming it does constitute a supply, it does not constitute the making of a supply for consideration (i.e., the Investor would not receive consideration in return for receiving the Profit Distribution). ... Similarly, the making of an additional Capital Contribution by all partners is not a taxable supply made for consideration, as no consideration (i.e., partnership interest, further right or enhancement) is received in return for doing so. ...
GST/HST Interpretation

28 April 2017 GST/HST Interpretation 154249 - Entitlement to claim Input Tax Credits (ITCs) as recipient of the supply

We also agree that the Assignee was liable to pay consideration for the supply of the Products made to [the Assignee] by the Vendor. ... The Assignee paid, on behalf of [X], the consideration for a supply of software licences made to [X]. ... Generally, the “recipient” of a supply is defined under subjection 123(1) to include, “(a) where consideration for the supply is payable under an agreement for the supply, the person who is liable under the agreement to pay that consideration, (b) where paragraph (a) does not apply and consideration is payable for the supply, the person who is liable to pay that consideration, and…” In determining who the recipient of a supply is, and who may therefore be entitled to an ITC for any tax payable on the supply, it is necessary to determine whether the supply is acquired by a person on its own behalf or as an agent on behalf of another person. ...

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