Section 6
Subsection 6(1)
Administrative Policy
CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 35
Conference example
ABC Co hosts a two day conference on the latest developments within a particular field and engages various experts to present...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 17 | fee for training session or seminar was for IPP | 253 |
Revenu Quebec "Place of Supply"
The place of supply determines whether the HST or the GST and QST apply. ...For more information on the application of the GST/HST, refer to...
17 January 2013 Ruling Case No. 130479
Members of a national organization (who provide their business address) pay annual fees for membership and separate fees for admissions to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 8 | contracting address referenced | 50 |
Section 7
Administrative Policy
June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"
Meaning of "can only be used"
The terms of the agreement for the supply governing the use of the rights generally determine the extent, if any, to...
Section 8
Administrative Policy
17 January 2013 Ruling Case No. 130479
Members of a national organization (who provide their business address) pay annual fees for membership and separate fees for admissions to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 6 - Subsection 6(1) | 130 |
13 June 2011 Headquarters Letter Case No. 133042
a supply of intangible personal property that can be used anywhere in Canada which is made by a non-resident supplier to a Canadian-resident...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Schedules - Schedule IX - Part II - Section 1 | place of legal delivery, e.g., under Incoterms, is referenced | 107 |
| Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(a) | Incoterm delivery terms | 107 |
18 May 2011 Headquarters Letter Case No. 123947
a resort developer supplies memberships that entitle a member to use certain real property at one or more resort locations located in Canada and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(c) | points to use resort units could be IPP or real property rights | 128 |
18 April 2011 Headquarters Letter Case No. 123466
the supply of memberships in an association would be governed by s. 8 as a supply of intangible personal property so that, for example, if in the...
Paragraph 8(b)
Administrative Policy
June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"
Includes Example 49 (lawyer operates a law firm in Ontario designates her Quebec home as the billing address but also provides the Ontario office...
23 November 2011 Ruling Case No. 131828
The supplier of specified time memberships to a social networking website does not obtain a home or business address of the recipients of the...
CBAO National Commodity Tax, Customs and Trade Section – 2011 GST/HST Questions for Revenue Canada, Q. 5
A Co is selling to B Co assets of a portion of its service/repair business which it carries on in Quebec and Ontario including goodwill (mostly, a...
Section 10
Administrative Policy
June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"
Ontario situs even though TPP predominantly in the U.S.
Example 72
A registered non-resident company supplies an Ontario company with intangible...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Subsection 13(1) | 117 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 14 | servicing three buildings to 2 provinces treated as single supply re s. 14 | 26 |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 15 | 103 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 27 | 129 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 28 | 32 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 8 - Paragraph 8(b) | Ontario office referenced only in website more closely connected than home billing address | 40 |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 7 | 126 |
Subsection 13(1)
See Also
Rochus Geissel, as liquidator of RGEX GmbH v Finanzamt Neuss (Neuss Tax Office), C 374/16, [2017] BVC 58 (European Court of Justice, 5th Chamber)
The Neuss Tax Office in Germany denied input tax claims of RGEX (which traded in motor vehicles) on its purchase of 122 motor vehicles on the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 3 - Paragraph 3(a) | policy met where registration of vendor can be verified | 75 |
Administrative Policy
16 February 2016 Ruling 165366 Dietetic Services
A dietician who is registered with the provincial College of Dietitians entered into a Service Agreement with a registered charity (the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Qualifying Health Care Supply | nutiritional consulting by licensed dietician not excluded | 152 |
| Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 7.1 | nutritional consulting supplied to registered charity exempted | 32 |
5 February 2016 Interpretation 153241
CRA considered that independent medical evaluations (IMEs) supplied by non-employee doctors to insurance companies or lawyers after March 21,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 5 | pre-2013 medical evauations for insurers generally exempt | 274 |
| Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Qualifying Health Care Supply | medical evaluations for insurers now excluded | 294 |
| Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(g) | doctor provided single supply of medical evaluation service to insurer so that all of fee taxable notwithstanding report writing outside Canada | 341 |
3 February 2014 Interpretation 126057
A registered non-resident (Company A) supplies services to X, many of whom have members which are located in various provinces and which have...
31 October 2011 Ruling Case No. 132350
A personnel services company (the Corporation) provides temporary and permanent staffing needs of its customers. Client 1 contracts with the...
June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"
Includes:
- Example 92 (the BC office of a corporation which receives the advice and had meetings with the advisor has a closer connection than the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 14 | servicing three buildings to 2 provinces treated as single supply re s. 14 | 26 |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 15 | 103 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 27 | 129 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 28 | 32 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 8 - Paragraph 8(b) | Ontario office referenced only in website more closely connected than home billing address | 40 |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 7 | 126 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 10 | 112 |
Section 14
Administrative Policy
12 December 2012 Interpretation Case No. 142112
A real estate broker based in Nova Scotia is hired by a company with a head office in Nova Scotia to lease real property in New Brunswick to a...
June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"
Includes Example 120 (maintenance services supplied re three buildings of equal size - two in New Brunswick and one in Quebec - are supplied in...
Section 15
Administrative Policy
16 March 2016 Ruling 158766
After ruling that “each [on-site and off-site] supply of [Service X] made by [ACo] is a service in relation to TPP that is made in the province...
June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"
Includes:
- Example 104 (a pet is tangible personal property, so that a veterinary service is made in the province where the pet is...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Subsection 13(1) | 117 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 14 | servicing three buildings to 2 provinces treated as single supply re s. 14 | 26 |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 27 | 129 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 28 | 32 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 8 - Paragraph 8(b) | Ontario office referenced only in website more closely connected than home billing address | 40 |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 7 | 126 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 10 | 112 |
Section 16
Administrative Policy
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 23. ("HST Place of Supply Rules – Legal Services")
A GST/HST-registered Canadian law firm performs legal services, as a single, bundled supply, on behalf of a Canadian lender in a secured financing...
Section 17
Administrative Policy
CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 35
Conference example
ABC Co hosts a two day conference on the latest developments within a particular field and engages various experts to present...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 6 - Subsection 6(1) | fee for training session or seminar was for IPP | 256 |
Section 20
Stopover
Administrative Policy
GST/HST Memorandum 28.3 Passenger Transportation Services July 2019
Round trip by ground back to Canada has no stopover if less than 24 hours
17. When determining the province in which the supply is made, a...
Section 21
Administrative Policy
GST/HST Memorandum 28.3 Passenger Transportation Services July 2019
Rule of origin
61. Generally, where the origin is specified on the ticket or voucher issued in respect of the first passenger transportation...
GST/HST Info Sheet GI-170 "Charter Flights Supplied to Third-Party Charterers" May 2015
Generally, a supply of a passenger transportation service that is part of a continuous journey is made in a participating province if the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| 351 | ||
| 117 | ||
| Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 3 | 429 | |
| Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 4 | 126 | |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | 181 |
Section 22
Subsection 22(1)
Administrative Policy
GST/HST Memorandum 28.3 Passenger Transportation Services July 2019
Application where rail pass can only be used in Ontario (para. 74)
Example 19
An individual resident of Ontario purchases a rail pass at a rail...
Section 23
Administrative Policy
GST/HST Memorandum 28.3 Passenger Transportation Services July 2019
Different tax rate on each leg of journey (para. 76)
Example 20
A traveller buys an airline ticket for travel from St. John’s, Newfoundland and...
Section 27
Administrative Policy
June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"
'The time when the administrative litigation commences will normally be based on the procedural requirements imposed by the relevant legislation,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Subsection 13(1) | 117 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 14 | servicing three buildings to 2 provinces treated as single supply re s. 14 | 26 |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 15 | 103 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 28 | 32 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 8 - Paragraph 8(b) | Ontario office referenced only in website more closely connected than home billing address | 40 |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 7 | 126 | |
| Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 10 | 112 |
Section 28
Administrative Policy
CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 35
Conference example
ABC Co hosts a two day conference on the latest developments within a particular field and engages various experts to present...
June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax - place of supply rules for determining whether a supply is made in a province"
Includes Example 120 (the provision of lighting and other special effects at a gala event event in Quebec is considered to be services performed...