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" Products commonly described as dietary supplements are not considered to be basic groceries. ... Although these products may contain some essential nutritional elements, they are not considered to be basic groceries. ...

Although the store is reimbursed by the XXXXX for accepting the Voucher as a coupon in exchange as full consideration of a supply of a XXXXX, the coupon is not considered to be a reimbursable coupon to which subsection 181(2) applies as there is no fixed dollar amount specified in the Voucher; instead, subsection 181(4) applies to the Voucher. ... The Voucher is considered to be a "coupon" as the term is defined and interpreted for purposes of section 181. ...

The Products in this case are therefore considered to be "similar snack foods" for purposes of paragraph 1(f) of Part III of Schedule VI. ... All factors must be considered in determining whether a product falls within paragraph 1(f) of Part III of Schedule VI. ...

Ruling Given Based on the facts set out above, we rule that the sale of the gift packages is not subject to GST/HST as they are considered to be gift certificates for purposes of section 181.2 of the ETA. ... Although, section 181.2 deems the sale of the gift certificate not to be a supply for GST/HST purposes, a person who makes that supply is still considered to be engaged in a commercial activity. ...

Although we consider product placement as a relevant consideration, it alone is not considered a determinative factor. ... The Product is considered to be "other similar snack foods" under paragraph 1(f). ...

Based on the facts, the Company is not considered to be carrying on business in Canada for purposes of the ETA. A non-resident person must have a significant presence in Canada to be considered to be carrying on business in Canada. ...

GST/HST Policy Statement P-051R2: Carrying on Business in Canada (available on the CRA website: (http://www.cra-arc.gc.ca/E/pub/gl/p-051r2) identifies various factors that are considered when determining whether a non-resident person is carrying on business in Canada for GST/HST purposes in a particular situation. ... Based on the application of the relevant factors set out in the policy to the facts, you were considered to be carrying on business in Canada for GST/HST purposes as a result of the service that you performed in Canada as described in the facts. ...

Ruling Given Based on the facts set out above, we rule that the sale of the XXXXX vouchers is not subject to GST/HST as they are considered to be gift certificates for purposes of section 181.2 of the ETA. ... Although, section 181.2 deems the sale of the gift certificate not to be a supply for GST/HST purposes, a person who makes that supply is still considered to be engaged in a commercial activity. ...

The Product in this case is therefore considered to be "similar snack foods" for purposes of paragraph 1(f) of Part III of Schedule VI. ... All factors must be considered in determining whether a product falls within paragraph 1(f) of Part III of Schedule VI. ...

Ruling Requested You would like to know if the procedure that you follow when issuing your "Factory Rebate" certificate meets the essential requirements for it to be considered a rebate for the purpose of section 181.1. Ruling Given Based on the facts set out above, we rule that the procedure that you follow when issuing your "Factory Rebate" certificate meets all the essential requirements to be considered a rebate within the meaning of section 181.1. ...