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The Association’s main office is located in [City 1] and would be considered a fixed place of activities as it is a determined location that can be identified with the Association, and the Association exercises control over that office and carries out its on-going charitable activities through that office on a regular and reoccurring basis. At the same time, the premises of the Members cannot be considered as fixed place of activities of the Association since, based on the available information, Members are independent in their daily operations, separate legal entities, and as stated in the Member Agreement, “the Members shall each have exclusive authority, control and responsibility for the Member’s activities within its territory…” However, there are other circumstances set out in subsection 400(2) of the Income Tax Regulations where a charity may be deemed to have a “permanent establishment” in a province. ...

To arrive at this conclusion, we considered information obtained from your letter, phone conversations with you, the sample agreement you have with parents/guardians, and the […][guidelines and mutual expectations between the parties]. ... There are numerous work elements, such as training or instruction, included as part of this overall supply of training plan/program design, however, we do not consider that these individual tasks or elements carry sufficient weight on their own to warrant being considered separate supplies. ...

As the Vendor has issued an invoice to the Assignee for the full purchase price of both the hardware and the software licences, [ABC] has considered that the Assignee was primarily liable under the Assignment to pay the consideration to the Vendor, and that the Assignee was the “recipient” of the supply and the one who was entitled to claim an ITC for the full amount of GST/HST charged on the Vendor’s invoice. […] […][It is Canada Revenue Agency (CRA)’s position] that the total amount invoiced by the Vendor and paid by the Assignee represents consideration for two different supplies (1) the first being the supply of the Products, title to which was subsequently assigned to the Assignee, and (2) the second being the supply of software licences made to [X], and for which consideration is paid by the Assignee on behalf of [X]. ... Consequently, the Assignee is not considered the recipient of the supply of software licences and is not entitled to claim an ITC for the GST/HST paid for them to the Vendor. ...

Where the Board sends the books to an address in Canada, the GST/HST would apply to both to the selling price of the books and the related shipping charges (the related shipping charges would be considered to be part of the amount payable for the books). ... Accordingly, the shipping of the books is considered to form part of the supply of the books and the same rate of GST/HST applies to both the amount payable for the books and the related shipping charge. ...

Regular sales of property or sales made in a business-like manner as demonstrated by extensive marketing and advertising, or the devotion of extensive time, attention and resources to the sale of the property, would normally be considered as sales made in the course of a business. ... When determining whether the activities of a person are undertaken to achieve a primary goal, factors to be considered include, but are not limited to: 1. the extent to which the activities have common factors (such as the same location, procedures, products, customers or clients, employees, equipment, etc.); 2. whether one activity exists primarily to support another; 3. whether the activities are accounted for and recorded in a single set of records throughout the year; and 4. whether the operations are treated as a whole for purposes other than the GST/HST (e.g., income tax purposes). ...

The business addresses obtained include the address of the [contractor] in [Province 3], which is considered to be the contracting address and consequently the address that is most closely connected with the supply of the IPP. ... The business addresses obtained include the address of the [contractor] in [Province 3], which is considered to be the contracting address and consequently the address that is most closely connected with the supply of the [...] service and the optional [...] service. ...

Strictly speaking, an option to acquire something is not necessarily the same as acquiring the thing itself and an option to acquire something is generally considered to be a supply. ... Therefore, the Optionor is considered to be providing natural resource rights in respect of an unproven property to the Optionee. ...

Section […] of the Lease Agreement states that all amounts which are payable by the Tenant to the Corporation pursuant to the lease shall be considered to be rent and all remedies from time to time available to the Corporation for the collection of rental shall apply. 13. ... The Tenant's reimbursement of municipal property taxes, and any other taxes or levies applicable to the Premises is also considered additional rent under the Lease Agreement. ...

EXPLANATION Upon entering into an agreement for the purchase and sale of a new residential condominium unit that has yet to be constructed, the purchaser is considered to have acquired an interest in the residential condominium unit. An assignment of such an agreement of purchase and sale is considered to be a supply by way of sale of the interest in the residential condominium unit. ...