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However, subsection 141.01(1.2) of the ETA provides that where a government grant is provided for the purpose of funding an activity of a registrant which results in the making of taxable supplies for no consideration, the grant is deemed for purposes of the section to be consideration for those supplies. Thus, the amounts the person receives from a grantor are deemed to be consideration for the person's taxable supplies. ... However, where the Organization makes supplies for no consideration the supplies would generally be exempt pursuant to section 10 of Part VI of Schedule V to the ETA. ...

RULING GIVEN Based on the facts set out above, we rule that 1. a payment received by the Association from a Partner that participates in the Program and who credits reward dollars to Association members or from a member acquiring additional reward dollars represents consideration for the taxable supply of a coupon rather than a gift certificate and, accordingly, the Association is required to collect GST/HST on the value of the consideration for the supply of the reward dollars; 2. when reward dollars are used by members to purchase property and services, the Association should treat the reward dollars as a reduction of the price of the property or service equal to the fixed dollar amount (the reward dollars) redeemed; and 3. the non-reimbursable coupon rules in subsection 181(3) apply where the Association treats the reward dollars used for a taxable supply of property or a service (other than a zero-rated supply) as a “partial cash payment that does not reduce the value of the consideration for the supply”. ... In determining which provision under section 181 applies to reward dollars, the characteristics of the coupon must be taken into consideration. In this case, where the reward dollars are accepted in full or partial consideration for a taxable supply other than a zero-rated supply, subsection 181(3) applies to the treatment of the redeemed reward dollars. ...

The term recipient of a supply of property or a service is defined under subsection 123(1) to mean, in part: (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.... XXXXX is liable to pay the consideration for the supply of the XXXXX to XXXXX; is the recipient of the supply of the XXXXX based upon the following facts: • The letter from XXXXX to XXXXX, dated XXXXX, states that XXXXX agreed to the purchase of the XXXXX, advanced $XXXXX toward the purchase, and was awaiting the final billing for the purchase. • XXXXX dated XXXXX, issued by XXXXX and sent to XXXXX indicates that the person who is liable to pay the consideration for the supply of the XXXXX is XXXXX • The letter from XXXXX to XXXXX dated XXXXX, requests payment for the balance owing XXXXX for the purchase of the XXXXX; the outstanding amount is $XXXXX for the GST payable on the supply. • In the XXXXX dated XXXXX, XXXXX indicates that XXXXX purchased and paid for the XXXXX. ... The documentation provided to us does not give evidence that XXXXX is liable to pay the consideration for the supply of the XXXXX to XXXXX; XXXXX is not the recipient of the supply by XXXXX of the XXXXX. ...

Ruling Given Based on the facts set out above, we rule that the accommodation tax imposed via XXXXX, effective XXXXX, of the City of XXXXX under the authority of XXXXX (a) is a "provincial levy" for purposes of section 154 of the ETA, and (b) is not a "prescribed provincial levy" enumerated in the Taxes, Duties and Fees (GST/HST) Regulations for purposes of section 154 of the ETA to be excluded from consideration for GST purposes- i.e. the accommodation tax is part of the consideration for the supply of the accommodation upon which GST is calculated. ... Accordingly, the accommodation tax imposed via the by-law under the authority of XXXXX is part of the consideration for GST purposes for the supply of the short-term accommodation. Generally, the supply of short-term accommodation is a taxable supply; the value of consideration upon which GST applies and is calculated is increased accordingly by the value of the accommodation tax. ...

We do not share the view that general principles could justify a reduction of consideration for the new supply. "Consideration" is defined under the ETA as including any amount payable for the supply by operation of law. ... Consequently, they are or form part of an amount "payable" for the new supply and part of consideration for the supply. 3. ...

If there is a direct link the transfer payment will be regarded as consideration. ... If it is owned by the XXXXX the XXXXX may be supplying construction services to the XXXXX and the payments under the CLA could be consideration for that supply. ... As the transfer payment is not consideration, XXXXX entitlement to relief should be determined without reference to that payment. ...

The consideration paid or payable includes any amount of tax payable by the supplier on the transaction, after input tax credits or rebates have been deducted. ... If the payment for "administrative services" is required to be paid as a condition of being a recipient of steam, the payment remains part of the consideration for the steam. 3. ... The consideration is paid for a single supply of steam that would be taxable, since the total amount of consideration would exceed Charity B's direct cost of the steam. 4. ...