State Farm Mutual Auto Insurance Co. v. The Queen,  GSTC 35
charges to Canadian branch of an allocated portion of head office expenses were not for services rendered
Head office expenses that the appellant allocated to its Canadian regional office were not deemed to be supplies of services given that there was no evidence that the head office rendered management or administration services to the Canadian regional office but instead provided its services for the benefit of customers of the whole organization. Further, if services were rendered at all, they related to a supply of financial services (underwriting).
|Locations of other summaries||Wordcount|
|Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service||119|
|Tax Topics - Excise Tax Act - Section 138||84|