Locations of other summaries		Wordcount
Tax Topics - General Concepts - Illegality	illogical to infer a tax benefit from illegal sales	153
Tax Topics - Statutory Interpretation - Headings	heading did not contemplate illegal drugs	100

Administrative Policy

Excise and GST/HST News - No. 97 17 November 2015

Importations of donor eggs

[S]upplies of human sperm and oocytes are not drugs that are included in section 2 of Part I of Schedule VI and...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Practitioner		287
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 7		139
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part II - Section 37		154
Tax Topics - Excise Tax Act - Section 225		90

GST Memoranda Series 4.1 "Prescription Drugs and Biologicals" ETA - Schedule VI Part II

GST M 300-4-2 "Health Care Services"

Paragraph 2(a)

Administrative Policy

8 March 2018 CBA Commodity Taxes Roundtable, Q.3

Although CRA’s position was that supplies of in vitro diagnostic test kits designed for laboratory use are taxable, the Centre Hospitalier Le...

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Paragraph 2(b)

Administrative Policy

Excise and GST/HST News - No. 101 March 2017

Hormonal, but not copper, intrauterine devices are zero-rated

Hormonal IUDs have a reservoir which slowly releases hormones used for...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Charity		146
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 5		310
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service		48
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Person		87

The Prescription Drug List

Paragraph 2(e)

Cases

Patterson Dental Canada Inc. v. Canada, 2020 FCA 40

The taxpayer sold anesthetic solutions containing epinephrine to dentists, and was assessed for failure to charge GST on the basis that such...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply	the single supply doctrine did not deem an anesthetic containing a drug substance to be that drug	143

Administrative Policy

Excise and GST/HST News - No. 108 September 2020

CRA’s existing policy re drugs with mixed substances is consistent with Patterson Dental

[Patterson Dental held] that the supply of epinephrine...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (c)		119
Tax Topics - Excise Tax Act - Section 232 - Subsection 232(3) - Paragraph 232(3)(a)		452
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Practitioner		82
Tax Topics - Excise Tax Act - Section 154 - Subsection 154(2) - Paragraph 154(2)(b)		101

Section 6

Administrative Policy

GST/HST Notice 312 Proposed GST/HST Treatment of Supplies of Human Ova and In vitro Embryos May 2019

Effect of zero-rating on importations

The first proposed amendment to the Act would add, under section 6 of Part I of Schedule VI to the Act, the...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VII - Section 13		390
Tax Topics - General Concepts - Effective Date	CRA allows immediate application of the new non-supply rules for human ova or embryos but won’t process rebate claims until passed	168
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Institutional Health Care Service	assimilation of provision of ovum or embryo to single supply at fertility clinic of institutional health care service	80

Part II

Section 9

Cases

Contact Lens King Inc. v. Canada, 2022 FCA 154

The appellant, a U.S. corporation, sold and delivered contact lenses (typically replacement contact lenses) to Canadian consumers without...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 286 - Subsection 286(1)	no particular form of documentary evidence required by s. 286(1)	228
Tax Topics - Income Tax Act - Section 230 - Subsection 230(1)	taxpayer flexibility to determine corroborative documents	103
Tax Topics - Statutory Interpretation - Inserting Words	not role of courts to add words	134

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 286 - Subsection 286(1)	failure to obtain and retain copies of customers' prescriptions did not comply with s. 286(1)	238

Section 11

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 5	supply of crown or other prosthesis by dentist was a single supply of a health care service	417
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Commercial Activity	para. (a) made exempt supplies paramount over zero-rated supplies	179
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply	dentist who was providing artificial teeth (listed as a zero-rated item) was making a single supply of health care services	346
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 34	legislative approach in VI-II-34 reinforced a conclusion that dental crown or implant work was an exempted service	66

Administrative Policy

21 August 2024 GST/HST Ruling 174773 - Tax status of the installation of artificial teeth by a dental practice

Regarding the supply by a dentist’s professional corporation of an artificial tooth (e.g., a denture, crown or bridge) to a patient, CRA applied...

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Section 11.1

Cases

Canada v. Dr. Kevin L. Davis Dentistry Professional Corporation, 2023 FCA 76

The respondent (Davis Dentistry) had claimed input tax credits (ITCs) on the basis that a portion of its supplies to each orthodontic patient was...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 5	orthodontist was supplying orthodontic services separately from zero-rated orthodontic devices	221
Tax Topics - Statutory Interpretation - Drafting Style	imprecise drafting is not typical of taxing statutes	101

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 3 - Paragraph 3(b)	invoices showing nil tax and not allocating between the included zero-rated and exempt supply complied with s. 3	369
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(5)	agreement with the Canadian Dental Association was an exercise of discretion under s. 169(5)	273

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 5	single supply by incorporated orthodontist of health care services	262
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Institutional Health Care Service - Paragraph (h)	single supply of orthodontic services by incorporated orthodontic practice qua health care facility	165
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply	single supply of orthodotic service	87
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Institutional Health Care Service - Paragraph (b)	orthodontic appliance was not a "medical prosthesis"	164

Administrative Policy

GST/HST Notice 339, “Input Tax Credits Related to Dental Practices,” October 2024

Administrative arrangement with the Canadian Dental Association

Under the CRA arrangement made in 1991 with the Canadian Dental Association, a...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1)	revocation of CRA administrative arrangement regarding ITC claims by orthodontic practices	237

7 April 2022 CBA Roundtable, Q.6

At the 2018 CBA Roundtable, Q.5 regarding Brian Hurd, and CRA’s administrative arrangement to allow 35% input tax credits to orthodontal...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply	CRA has postponed proceeding with treating orthodontists as making a single exempt supply	182

Section 24.1

Locations of other summaries		Wordcount
Tax Topics - General Concepts - Onus	mixed assumptions of fact and law	189

Section 32

Section 33

Administrative Policy

Excise and GST/HST News, No. 104, July 2018

The following are considered service animals for purposes of section 33:

seeing-eye horses (miniature ponies);

seeing-eye dogs;

hearing-ear...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Insurance Policy		293
Tax Topics - Excise Tax Act - Section 154 - Subsection 154(2)	GST on B.C. sales tax applicable to sales of expensive autos	259
Tax Topics - Excise Tax Act - Regulations - Taxes, Duties and Fees (GST/HST) Regulations - Section 3 - Paragraph 3(b)		74

Section 34

Administrative Policy

4 May 2021 GST/HST Ruling 199267 - Tax paid on construction services

CRA found that a registered charity received a single supply of renovation work notwithstanding that an identified component of the work was...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply	renovation work constituted a single supply so that component wheelchair hoist work was not zero-rated	246

Section 37

Administrative Policy

Excise and GST/HST News - No. 97 17 November 2015

Design features must assist in coping with incontinence

To be an incontinence product specially designed for use by an individual with a...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Practitioner		287
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 7		139
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part I - Section 2		70
Tax Topics - Excise Tax Act - Section 225		90

Part III

Section 1

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(2)		64

Administrative Policy

29 March 2017 Ruling 183173

In finding that a bottled product that was to be mixed with water did not qualify under Sched. VI, Pt II, s. 1, CRA stated:

[T]he CRA considers a...

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GST/HST Technical Information Bulletin B-110 Application of the GST/HST to the Practice of Acupuncture April 2017

Separate supplies of herbal goods by acupuncturist

Sales of products such as dried herbs and herbal goods for medicinal purposes are generally...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 7		527
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Practitioner		89
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply		318
Tax Topics - Excise Tax Act - Section 186 - Subsection 186(1)		49

Paragraph 1(e)

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(f)	fried sticks were sold as snack and were not baked	233
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(h)	granola in cereal aisle intended primarily as breakfast cereal	194

Paragraph 1(f)

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(e)	crystallized ginger sold as baking ingredient rather than candy	251
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(h)	granola in cereal aisle intended primarily as breakfast cereal	194

Paragraph 1(h)

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(e)	crystallized ginger sold as baking ingredient rather than candy	251
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(f)	fried sticks were sold as snack and were not baked	233

Paragraph 1(k)

Part V

Section 1

Administrative Policy

8 March 2018 CBA Commodity Tax Roundtable, Q.9

Company B, a registered resident, agreed to sell tangible personal property (the “Property”) to Company C, an unregistered non-resident, using...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(2) - Paragraph 142(2)(a)	Incoterms did not govern the place of delivery of goods	163

GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014

Overview of requirements

3. A supply of tangible personal property (other than an excisable good) made by a person to a recipient (other than a...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 12		138
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 14		73
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.1		197
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.2		144
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 6.1		195
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 2		121
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(6)		282
Tax Topics - Excise Tax Act - Subsection 218.1 - Subsection 218.1(1) - Paragraph 218.1(1)(b)		145
Tax Topics - Excise Tax Act - Section 236.1		131

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 1

Where the taxpayer has failed to provide information pursuant to a requirement under s. 289.1, "CRA's general policy is to proceed with a...

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94 CPTJ - Q. 1

RC will be amending its administrative policy to allow certificates to be issued by purchasers containing prescribed information as evidence of...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(3)		11
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x)		17
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2)		35

Section 2

Administrative Policy

GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014

Example 3

An unregistered non-resident airline is supplied with meals for consumption on board, and parts used to operate the aircraft while the...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 12		138
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 14		73
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.1		197
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.2		144
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 1		692
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 6.1		195
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(6)		282
Tax Topics - Excise Tax Act - Subsection 218.1 - Subsection 218.1(1) - Paragraph 218.1(1)(b)		145
Tax Topics - Excise Tax Act - Section 236.1		131

Paragraph 2(a)

Administrative Policy

7 April 2022 CBA Roundtable, Q.14

Does Sched. VI, Pt. V, s. 2 zero-rate all property that is purchased or leased by a non-resident airline whose sole activity is to carry on the...

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Words and Phrases

in the course of

Section 5

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 306	an appeal of 12 assessments that is joined under Rule 25 retains its character as an appeal of 12 assessments	194
Tax Topics - General Concepts - Agency	agency implied on the basis of conduct/ acts of agent were those of principal	173
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Institutional Health Care Service	services provided by Canadian agent on behalf of a Mexican hospital were not exempted under V‑II‑2 because they were performed in part out of its (non-hospital) Canadian facilities	122
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(g)	services performed by Mexican hospital were partly performed in Canada by virtue of its Canadian agent, so that their place of supply under s. 142(1)(g) was in Canada	147
Tax Topics - Excise Tax Act - Section 143 - Subsection 143(1)	Mexican hospital was carrying on business in Canada by reason of its Canadian agent’s activities	288

Administrative Policy

16 March 2018 Ruling 158124

As a small part of its business, a U.S. resident who is not registered for GST/HST purposes (“USco”) supplies information services to Canadian...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1)	USco’s use of a Canadian affiliate for substantial marketing support for web-delivered services did not constitute carrying on business in Canada	446
Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b)	USco not carrying on business in Canada by virtue of extensive marketing assistance (without client contact) work provided by Canadian affiliate	234

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 17. ("Supplier Reliance on Purchaser Certificates")

Respecting a certificate of a non-resident that it is not carrying on business in Canada:

CRA has not indicated in GST/HST Memorandum 4.5.1, nor...

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Section 6.1

Administrative Policy

8 March 2018 CBA Commodity Tax Roundtable. Q. 17

In the railway industry, maintenance orders generally are tracked as either scheduled maintenance - or as “bad orders,” being for repair...

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Words and Phrases

emergency

GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014

Emergency

38. The term "emergency" is not defined in the Act but generally refers to an unforeseen event or combination of events that calls for...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 12		138
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 14		73
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.1		197
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.2		144
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 1		692
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 2		121
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(6)		282
Tax Topics - Excise Tax Act - Subsection 218.1 - Subsection 218.1(1) - Paragraph 218.1(1)(b)		145
Tax Topics - Excise Tax Act - Section 236.1		131

Section 6.3

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Precious Metal	market criteria for gold to be in investment form	312

Section 7

Cases

Canada v. Adboss, Ltd., 2023 FCA 201

The Minister’s reply, to the taxpayers’ appeals of assessments denying zero-rating of taxable supplies made by them to a Cyprus company...

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Locations of other summaries		Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 53 - Subsection 53(1) - Paragraph 53(1)(c)	the Minister’s assumption that a company’s “controlling mind and management” was in Canada was an abuse of process	184

Locations of other summaries		Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 53 - Subsection 53(1) - Paragraph 53(1)(c)	assumption that a company’s “controlling mind and management” was in Canada struck as a mixed statement of fact and law	239

Administrative Policy

8 December 2022 GST/HST Interpretation 222719 - Supplies of digital marketing services made to a non-resident

A resident registrant (CanCo) provided, to non-resident clients from a location in Canada, digital advertising, digital marketing, content...

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Words and Phrases

advisory service

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 8	digital marketing services were not zero-rated	391
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 23	meaning of professional service	204

"GST/HST In Electronic Commerce", CCRA Discussion Paper, November 2001.

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 143 - Subsection 143(1)		0

23 October 2000 Interpretation 11640-1

The Canadian operator of an internet auction site would be considered, with respect to non-resident vendors, to be arranging for, procuring or...

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GST/HST Memorandum 4.5.1 “Exports - Determining Residence Status” January 1998

Supplier responsible for determining zero-rated residency status of recipient including s. 132(2) branches

Non-resident requirement

3. Along with...

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6 May 1998 HQ Letter

administrative services provided to an RRSP with a non-resident beneficiary and a resident trustee will be zero-rated if paid for by the annuitant...

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Paragraph 7(d)

Administrative Policy

GST/HST Memorandum 4.5.3 “Exports – Services and Intellectual Property” June 1998

Principles re "in respect of" exclusion

Determining connection between service and property

46. The following guidelines help in determining...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 10		61

Paragraph 7(f)

Administrative Policy

28 February 2019 CBA Roundtable, Q.8

A registered non-resident (NR) does not itself have any presence in Canada but uses a resident (sub)contractor (RC) to provide marketing and...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(g)	registered non-resident marketer using services of a Canadian subcontractor was thereby making supplies in Canada	148

Section 8

Administrative Policy

8 December 2022 GST/HST Interpretation 222719 - Supplies of digital marketing services made to a non-resident

A resident registrant (CanCo) provided, to non-resident clients from a location in Canada, services comprised of digital advertising, digital...

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Words and Phrases

advertising

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 7	meaning of advisory service	222
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 23	meaning of professional service	204

Section 10

Locations of other summaries		Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 12	incidental use of copyright in acquiring data did not create a copyright supply	119

Administrative Policy

B-090 "GST/HST and Electronic Commerce" July 2002

Software zero-rating (Example 1 under Supplies Made to Non-Residents)

[T]he supply of software is a supply of intellectual property.

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 10.1		138

GST/HST Memorandum 4.5.3 “Exports – Services and Intellectual Property” June 1998

Example -zero-rating of global database (para. 51)

Canadian company sells the international rights to operate a global database to a foreign...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 7 - Paragraph 7(d)		697

29 October 1997 Ruling HQR0000558

Respecting the provision of CD-ROM discs containing databases and software permitting the retrieval of the data, protected by copyright, CRA...

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Articles

James Swanson, David Ross, "Taxing Intangibles - GST and the Supply of Digital Images", GST & Commodity Tax, Vol. XVII, No. 4, May 2003, p. 25.

Section 10.1

Administrative Policy

8 April 2016 Ruling 158060

A non-resident lawyer who does not practise law in Canada is a “not in Province” member of a specified Class of a provincial law society, and...

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CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 33. ("Application of S. 10.1, Sch. VI, P. V – Service Related to Intangible Personal Property")

A Canadian GST-registered supplier sells custom software that it has been using to perform a service electronically, with such supplies being made...

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2 November 2012 Ruling Case No. 140160

Operator, a registered resident of province 1, has developed a program that consists of a secure network and various business, communications and...

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14 February 2012 Ruling Case No. 99181 [non-exclusive information use rights]

A Canadian company which is a registrant (the "Resident Supplier") enters into an agreement with a non-registered non-resident company to supply...

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4 February 2012 Ruling Case No. 99181 [information licence]

A resident supplier agrees to supply an unregistered non-resident recipient with the non-exclusive use rights to information belonging to the...

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GST/HST Info Sheet GI-034 "Exports of Intangible Personal Property" April 2007

Examples of supplies of IPP that will now be eligible for zero-rating under the proposed provision include:

subscriptions to Web sites that...

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B-090 "GST/HST and Electronic Commerce" July 2002

Factors that generally indicate that a supply made by electronic means is one of intangible personal property are:

a right in a product or a...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 10		27

Section 12

Cases

Escape Trailer Industries Inc. v. Canada (Attorney General), 2020 FCA 54

When a B.C.-based company (the “applicant”) sold an RV to a U.S. customer, it could have avoided the requirement to charge HST on the sale...

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Locations of other summaries		Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Financial Administration Act - Section 23 - Subsection 23(2)	CRA had not unreasonably referenced the specific requirements of the zero-rating provision	249

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 168 - Subsection 168(9)	meaning of deposit adopted	55

Administrative Policy

GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014

Common carrier

19. A "common carrier" is not defined in the Act but generally refers to a person engaged in the business of transporting property...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 14		73
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.1		197
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.2		144
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 1		692
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 6.1		195
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 2		121
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(6)		282
Tax Topics - Excise Tax Act - Subsection 218.1 - Subsection 218.1(1) - Paragraph 218.1(1)(b)		145
Tax Topics - Excise Tax Act - Section 236.1		131

Paragraph 12(a)

Cases

Montecristo Jewellers Inc. v. Canada, 2020 FCA 12

Customers would purchase watches or jewellery at Vancouver stores of the appellant in order to take them as gifts on their regular trips to China....

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(a)	“delivery” for ETA purposes had its meaning under the Sale of Goods Act	353

Montecristo Jewellers Inc. v. The Queen, 2019 TCC 31, aff'd 2020 FCA 12

Customers would purchase watches or jewellery at Vancouver stores of the appellant in order to take them as gifts on their regular trips to China....

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Words and Phrases

shipped contract of carriage carrier

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(a)	delivery in Canada as full voluntary transfer of possession there	328

Section 14

Administrative Policy

GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014

Example 8

A manufacturer in Canada charges its customers for moulds required in manufacturing a specific product. The moulds remain in Canada but...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 12		138
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.1		197
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.2		144
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 1		692
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 6.1		195
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 2		121
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(6)		282
Tax Topics - Excise Tax Act - Subsection 218.1 - Subsection 218.1(1) - Paragraph 218.1(1)(b)		145
Tax Topics - Excise Tax Act - Section 236.1		131

Section 15.1

Administrative Policy

May 2016 Alberta CPA Roundtable, GST Q.1

What documentation satisfies Sch. VI, Pt. V, s. 15.1? CRA responded:

In order for the "first seller" to zero-rate the supply of the continuous...

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GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014

62. Continuous transmission commodities situated in Canada are frequently exchanged for similar commodities situated outside Canada. For example,...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 12		138
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 14		73
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.2		144
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 1		692
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 6.1		195
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 2		121
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(6)		282
Tax Topics - Excise Tax Act - Subsection 218.1 - Subsection 218.1(1) - Paragraph 218.1(1)(b)		145
Tax Topics - Excise Tax Act - Section 236.1		131

Section 15.2

Administrative Policy

GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014

69. If the recipient subsequently neither exports the commodity as described in paragraph 15.2(a), nor supplies it as described in paragraph...

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Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 12		138
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 14		73
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 15.1		197
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 1		692
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 6.1		195
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 2		121
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(6)		282
Tax Topics - Excise Tax Act - Subsection 218.1 - Subsection 218.1(1) - Paragraph 218.1(1)(b)		145
Tax Topics - Excise Tax Act - Section 236.1		131

5 February 2013 Ruling Case No. 141852

Company A (a Canadian-resident registrant) sells crude oil for its market value to Company B (its U.S.-resident affiliate and also a registrant),...

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GST Memorandum (New Series) 3.7 (Draft), February 2012 para. 1040105: General Discussion. 2 August 2001 TI RITS 32561

"Where a registrant receives a zero-rated supply of natural gas intended for export and a taxable supply of natural gas that is not zero-rated...

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Section 18

Administrative Policy

GST/HST Memorandum 20-8 “Educational Services Made to a Non-resident” December 2019

Meaning of competence to perform a trade

4. The CRA will consider a course to provide individuals with the competence to practise or perform a...

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GST/HST Memorandum 20-1 "School Authorities - Elementary and Secondary Schools" December 2019

No requirement that supplier be a school authority

34. Although section 18 of Part V of Schedule VI is similar to section 8 of Part III of...

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Section 20 Paragraph 20(c)

Administrative Policy

3 April 2019 GST/HST Ruling 188947 - Tax status of supplies made by a municipality

The Municipality, which issues Building Permits for the construction of new buildings or major renovations to ensure compliance with local...

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Subparagraph 20(1)(c)(ii)

Administrative Policy

3 April 2019 GST/HST Ruling 188947 - Tax status of supplies made by a municipality

A Municipality, after reviewing an application for a liquor licence, charges fees in order to provide comments and recommendations to BC’s...

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Section 22

Section 23

Administrative Policy

8 December 2022 GST/HST Interpretation 222719 - Supplies of digital marketing services made to a non-resident

A resident registrant (CanCo) provided, to non-resident clients from a location in Canada, digital advertising, digital marketing, content...

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Words and Phrases

professional service

31 August 2004 Headquarter Letter - RITS 50657

In indicating that legal services provided to a non-resident manufacturer to defend it against product liability claims would be zero-rated, the...

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24 July 2003 Ruling Case No. 41660

Preparation of written appraisals of specific real properties located in Canada were "in respect of" such properties and, accordingly, were not...

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9 April 2001 T.I. 33818

Professional services provided to a non-resident insurer with regard to the liability of the non-resident insurer under an insurance contract...

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P-169R Meaning of in Respect of Real Property Situated in Canada and in Respect of Tangible Personal Property that is Situated in Canada at Time the Service is Performed, for Purposes of Schedule VI, Part V, Sections 7 and 23 to the Excise Tax Act

"In respect of" criteria

The following guidelines will be applied by the Department to aid in the determination of whether the connection between...

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15 June 2000 Headquarters Letter RITS 31364

A legal account rendered to a non-resident insurer was not zero-rated because the services were in respect of the defence of an individual...

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1 September 1999 Headquarters Letter RITS HQR0001873

Ruling that a contingency fee charged to a non-resident could be pro-rated based on the litigation services provided by the law firm before and...

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Memorandum (New Series) 4-5-3 "Export - Services and Intellectual Property" June 1998

48. The following are examples of services that are considered to be in respect of real property for purposes of Part V of Schedule VI:

(a)...

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Part VI

Part VII

Section 1 Subsection 1(1)

Continuous Journey

Administrative Policy

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019

Continuous journey where 1 ticket agent issues 2 tickets with 3-hour stopover (para. 6)

Example 4

An individual travels by bus from Windsor,...

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GST/HST Info Sheet GI-170 "Charter Flights Supplied to Third-Party Charterers"May 2015

Continuous journey

[T]he supply of a "passenger transportation service" is a supply of a service of transporting or carrying travellers (i.e., an...

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Freight Transportation Service

Stopover

Administrative Policy

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019

Interruption under 24 hours generally not a stopover

14. An interruption between 2 legs of a journey to transfer between conveyances is not...

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GST/HST Info Sheet GI-170 "Charter Flights Supplied to Third-Party Charterers"May 2015

"Stopover", in respect of a continuous journey of an individual or group of individuals, means any place at which the individual or group embarks...

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Subsection 1(1)

Section 2

Administrative Policy

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019

Exclusion if day trip returning to Canada

40. Specifically excluded from this zero-rating provision is a passenger transportation service that is...

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Section 3

Administrative Policy

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019

Bus trip to Seattle and plane flight to Lima form continuous journey (para. 41)

Example 11

A bus ticket for return travel from Vancouver, British...

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GST/HST Info Sheet GI-170 "Charter Flights Supplied to Third-Party Charterers"May 2015

Distinction between passenger transportation service to the public, who are independent of the operator, and lease of aircraft

Passenger...

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Section 4

Administrative Policy

GST/HST Info Sheet GI-170 "Charter Flights Supplied to Third-Party Charterers"May 2015

[T]he excess valuation charges for baggage would be viewed as a separate charge in respect of a passenger's baggage and not part of the...

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Section 5

Administrative Policy

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019

Zero-rating of charge for extending ticket (para. 55)

55. Where the supplier of a passenger transportation service provides a service (listed in...

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Section 8

Section 11

Administrative Policy

20 June 2024 GST/HST Ruling 247341 - Delivery services provided through […][the Platform]

The platform, through which consumers agree to make purchases of goods from merchants, makes deliveries of the purchased goods pursuant to a...

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Words and Phrases

interlining carrier

Section 15

Administrative Policy

27 April 2018 Ruling 185888

The Corporation provides medical repatriation services which involve arranging to transport an individual (the patient) from a foreign hospital to...

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Words and Phrases

ambulance

Part IX

Section 1

Cases

Bank of Montreal v. Canada (Attorney General), 2020 FC 1014, aff'd 2021 FCA 189

Before going on to find that the Minister’s decision to reject (under s. 141.02(20)) the request of the registrant (“BMO”) for approval of...

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National Bank Life Insurance v. Canada, 2006 FCA 161

The appellant provided administrative services to a non-resident company (Natcan) which operated in the reinsurance field and for which the...

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Administrative Policy

17 December 2015 Interpretation 153009

A corporation, which is not engaged exclusively in commercial activities, issues shares and pays dividends to its shareholders, who are both...

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11 July 1997 Technical Interpretation HQR0000416

Sales commissions and trailer fees received by a dealer who sells units in a mutual fund to non-resident investors would be zero-rated.

Guide for Providers of Financial Services under "Zero-rated Financial Services"

General synopsis of ss.1 and 2.

Articles

David Schlesinger, "De Minimis Financial Institutions", 1995 Commodity Tax Symposium Papers, C. 17: Danny Cisterna, "Hot Topics for Financial Institutions," 1999 Commodity Tax Symposium Papers, C. 7: suggests that "relates to" requires a direct connection.

indicates that an investment by a financial institution in dividend-bearing treasury shares of a non-resident company is a zero-rated supply.

Paragraph 1(a)

Subparagraph 1(a)(ii)

Paragraph 1(e)

Administrative Policy

25 March 2021 CBA Commodity Taxes Roundtable, Q.4

Are supplies of VPI by financial institutions to non-resident persons zero-rated? CRA responded:

We note that paragraph 1(e) of Part IX of...

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Section 2 Paragraph 2(d)

Cases

Northbridge Commercial Insurance Corporation v. Canada, 2023 FCA 211

The appellant (“Northbridge”) issued fleet insurance policies to trucking companies who operated their vehicles in both Canada and the U.S....

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Words and Phrases

risks insurance

Section 3

Administrative Policy

Guide for Providers of Financial Services

Any supply of precious metals not described in s. 3 will be treated as a supply of a financial service.

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - School Authority		71
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 1 - Elementary or Secondary School Student		225
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 2		388
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 3		375
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 4		848
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 5		112
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 7		112
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 7.1		178
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 11		67
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part III - Section 16		380

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 20 - Paragraph 20(c)	exemption for building permits does not extend to charges for extra inspections or reviews or overtime	241
Tax Topics - Excise Tax Act - Section 146	additional building inspection charges of municipality were taxable	88

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 24		202
		82
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 1 - Subsection 1(1) - Stopover		82
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 20 - Stopover		73
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 2		140
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 3		151
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 5		153
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 21		238
Tax Topics - Excise Tax Act - Schedules - Schedule IX - Part VI - Section 4.1		80
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 22 - Subsection 22(1)		141
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 23		115
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Taxi Business		174

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations - Section 21		322
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 1 - Subsection 1(1) - Stopover		123
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 4		132
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply		193
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 3		356

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(2) - Paragraph 142(2)(a)	trucking company was considered to make an immediate on-supply of fuel to truckers in the country where it acquired fuel at service stations	427
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(2) - Paragraph 142(2)(g)	apportionment of trans-border supplies of maintenance services	213

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 20 - Paragraph 20(c) - Subparagraph 20(1)(c)(ii)	fees for Municipality reviewing liquor licence application, including any public consultation charges, were exempt	86
Tax Topics - Excise Tax Act - Section 146	additional building inspection charges of municipality were taxable	88

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 3	Alberta bus tours were not part of continuous journey entailing continuous flight	102
	international flight tickets were not issued by agents for Canadian bus tour operator	76

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply	medical escort services were single supply	225
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 6	medical escort services could be single supply of nursing services where nurse etc. involved	208
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 5	medical escort services could be single supply of physician’s services where physician involved, but not including delegated paramedic services	228

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(5)	flexibility in choice of ITC allocation method for non-FIs	116
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (d)	borrowing and paying interest is the supply of a financial service	144
Tax Topics - Excise Tax Act - Section 141.02 - Subsection 141.02(18)	Minister's rejection of bank's proposed methodology based on perceived distortions, was reasonable	478

Locations of other summaries		Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply	required shareholder communications not a supply	177
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f)	dividend a financial supply to recipient	87
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (d)	share issuance a financial supply to shareholder	170

Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1.11)	issue should be stated "reasonably"	131
Tax Topics - Excise Tax Act - Section 141.02 - Subsection 141.02(21)	pre-approval of method for allocating inputs between foreign and domestic supplies did not stop CRA from assessing to deny zero-rating of the foreign supplies	202
Tax Topics - Excise Tax Act - Section 141.02 - Subsection 141.02(31) - Paragraph 141.02(31)(f)	s. 141.02(31)(f) is merely confirmatory of normal taxpayer onus	98
Tax Topics - Excise Tax Act - Section 141.02 - Subsection 141.02(1) - Direct Input	expenses of redeeming credit card loyalty points were inextricably linked to the issuer’s extension of credit, and only remotely linked to its earning zero-rated interchange fees	368
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1)	expenses of redeeming credit card loyalty points were an integral component of the issuer’s extension of credit, and not sufficiently connected to earning interchange fees	181
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient	merchant acquirer was the recipient of credit card interchange services even though it was a conduit to the merchant	156
Tax Topics - Statutory Interpretation - Exclusionary provisions	exclusionary provisions should be narrowly construed	267
Tax Topics - Excise Tax Act - Section 301 - Subsection 301(1.2) - Paragraph 301(1.2)(a)	taxpayer not precluded from raising an argument that the Minister was bound by an ITC method that it had described in detail in its pleadings	175

You are here

Schedule VI

Table of Contents

Part I

Section 2

Cases

Hedges v. Canada, 2016 FCA 19

See Also

Hedges v. The Queen, 2014 TCC 270, aff'd 2016 FCA 19

Administrative Policy

Excise and GST/HST News - No. 97 17 November 2015

GST Memoranda Series 4.1 "Prescription Drugs and Biologicals" ETA - Schedule VI Part II

GST M 300-4-2 "Health Care Services"

Paragraph 2(a)

Administrative Policy

Paragraph 2(b)

Administrative Policy

Excise and GST/HST News - No. 101 March 2017

Paragraph 2(e)

Cases

Patterson Dental Canada Inc. v. Canada, 2020 FCA 40

See Also

Patterson Dental Canada Inc. v. The Queen, 2018 TCC 112, aff'd 2020 FCA 40

Administrative Policy

Excise and GST/HST News - No. 108 September 2020

Section 6

Administrative Policy

GST/HST Notice 312 Proposed GST/HST Treatment of Supplies of Human Ova and In vitro Embryos May 2019

Part II

Section 9

Cases

Contact Lens King Inc. v. Canada, 2022 FCA 154

See Also

Contact Lens King Inc. v. The Queen, 2020 TCC 71, aff'd on other grounds 2022 CAF 154

Section 11

See Also

Axelrod v. The King, 2022 TCC 157 (Informal Procedure)

Administrative Policy

Section 11.1

Cases

Canada v. Dr. Kevin L. Davis Dentistry Professional Corporation, 2023 FCA 76

See Also

Dr. Kevin L. Davis Dentistry Professional Corporation v. The Queen, 2021 TCC 25, aff'd 2023 FCA 76

Dr. Brian Hurd Dentistry Professional Corporation v. The Queen, 2017 TCC 142 (Informal Procedure)

Administrative Policy

GST/HST Notice 339, “Input Tax Credits Related to Dental Practices,” October 2024

Section 24.1

See Also

Health Quest Inc v. The Queen, 2014 TCC 211 (Informal Procedure)

Section 32

See Also

Tremblay v. The Queen, [2001] GSTC 64 (TCC) (Informal Procedure)

Section 33

Administrative Policy

Excise and GST/HST News, No. 104, July 2018

Section 34

See Also

Buccal Services Ltd. v. The Queen, [1994] GSTC 70 (TCC)

Administrative Policy

Section 37

Administrative Policy

Excise and GST/HST News - No. 97 17 November 2015

Part III

Section 1

See Also

River Road Co-Op Ltd. v. The Queen, [1995] GSTC 34 (TCC)

Administrative Policy

29 March 2017 Ruling 183173

GST/HST Technical Information Bulletin B-110 Application of the GST/HST to the Practice of Acupuncture April 2017

Paragraph 1(e)

See Also

Ike Enterprises Inc. v. The Queen, 2017 TCC 59

Paragraph 1(f)

See Also

Ike Enterprises Inc. v. The Queen, 2017 TCC 59

Paragraph 1(h)

See Also

Ike Enterprises Inc. v. The Queen, 2017 TCC 59

Paragraph 1(k)

See Also