Section 181 - Coupons and Rebates

Subsection 181(1) - Definitions

Coupon

Cases

Tele-Mobile Company Partnership v. Canada, 2013 FCA 149, aff'g 2012 TCC 256

The appellant, a registered cellphone service provider ("TM"), offered customers "Billing Credits" when they signed up for longer term contracts...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 181.1 216

See Also

Nestlé Canada Inc. v. The Queen, 2017 TCC 33

The appellant claimed input tax credits under ETA s. 181(5) on the payment of the value of “instant rebate coupons” (IRCs) on different...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 232.1 reductions in sales price to refund discounts provided by wholesaler were promotional allowances 192
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. acceptance of oral Crown statement as to provision's purpose 128

Royal Bank of Canada v. The Queen, [2007] GSTC 122, 2007 TCC 281

A Canadian airline ("CAIL") entered into an agreement with the appellant ("RBC") to promote use of RBC's credit card and to honour frequent flyer...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) taxable supply of frequent flyer points 146
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply taxable supply of frequent flyer points 207
Tax Topics - Excise Tax Act - Section 181.2 frequent flyer points not gift certificates 121
Tax Topics - Excise Tax Act - Section 278 - Subsection 278(2) s. 278(2) precluded direct collection on assessment of recipient until supplier released from remittance obligation under CCAA 330
Tax Topics - Excise Tax Act - Section 296 - Subsection 296(1) - Paragraph 296(1)(b) no double taxation in s. 296(1)(b) assessment of purchaser because supplier had been released from its remittance obligation under CCAA plan 262

Administrative Policy

31 July 2023 GST/HST Interpretation 217772 - Complimentary gift cards

A supplier issues, to purchasing customers, supplier-branded gift cards with a monetary exchange value stored electronically on the card. The...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 181.2 bifurcation of a gift card between the complimentary coupon portion and the purchased gift certificate portion 241

23 April 2013 Ruling Case No. 141283 ["gift certificates" applied to purchases up to dollar maximum]

USco is a US-based company which sells vouchers (labeled as "gift certificate") to employers who in turn give them to their employees as holiday...

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19 April 2011 Interpretation 112537

In order to promote and encourage customer loyalty, A Co. established and maintained a "points" system (the "Loyalty Points"). Customers may earn...

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25 February 2005 Ruling Case No. 56925 [discount not a device]

An electronic discount made available by the manufacturer to all purchasers of the particular product from the retailer would not be considered to...

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GST M 300-7 "Value of Supply" under "Coupons"

Because the payment or receipt of the reimbursement is deemed not to be a financial service, it will not affect the third party's eligibility to...

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Subsection 181(2) - Acceptance of Reimbursable Coupon

Administrative Policy

7 April 2022 CBA Roundtable, Q.19

Aco sells taxable goods under its brand to a network of independent dealers managed by Bco, and also to Bco for sale by it or for resale to such...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 181 - Subsection 181(5) payments made for loyalty points that had been applied to receive free services without a fixed dollar amount, did not generate ITCs 774

27 February 2020 CBA Roundtable, Q.25

A general discussion, based on an incomplete set of facts, indicating that if an emailed promo code was a coupon as defined in s. 181(1), it would...

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GST M 300-7 "Value of Supply" under "Manufacturers' Rebates"

General synopsis. GST will apply to co-operative advertising payments in the normal manner.

GST M 300-7-6 "Manufacturers' Rebates"

Subsection 181(3) - Acceptance of Non-Reimbursable Coupon

See Also

Tele-Mobile Company Partnership v. The Queen, 2012 TCC 256, aff'd 2013 FCA 149

The appellant, a registered cellphone service provider ("TM"), offered customers "Billing Credits" when they signed up for longer term contracts...

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Words and Phrases
evidenced in writing coupon

Subsection 181(4) - Acceptance of Other Coupons

Administrative Policy

28 March 2002 Interpretation 34565

A member of a frequent flyer award program exchanged accumulated credits (XXXXX Miles) in exchange for an award ticket for travel within North...

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Subsection 181(5)

See Also

President's Choice Bank v. The Queen, 2022 TCC 84

A corporation (“PC Bank”) in the Loblaw group, whose business was to grant credit through the operation of a MasterCard program, obtained the...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.3) automated credit and fraud processing services provided to credit card company were excluded under para, (r.3) 263
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (t) automated credit and fraud monitoring services were likely excluded under para. (t) 189

Administrative Policy

7 April 2022 CBA Roundtable, Q.19

Company A sells goods in taxable supplies under its brand to a network of independent dealers managed by Company B, and also to Company B for sale...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 181 - Subsection 181(2) coupon rules applicable to loyalty points applied to acquire goods at a discount, or goods with a free service 357