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...
| 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...
| 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...
| 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...
| 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...
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...
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...
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...
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...
| 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...
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...
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...
Subsection 181(5)
Cases
President's Choice Bank v. Canada (the King), 2024 FCA 135
A corporation (“PC Bank”) in the Loblaw group, whose business was to grant credit through the operation of a MasterCard program, obtained the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | s. 169(1) requires apportionment of an acquisition of a property or service between commercial and exempt activity | 72 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Commercial Activity | commercial activity of corporation can be at a loss | 144 |
See Also
President's Choice Bank v. The Queen, 2022 TCC 84, rev'd 2024 FCA 135
A corporation (“PC Bank”) in the Loblaw group, whose business was to grant credit through the operation of a MasterCard program, obtained the...
| 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...
| 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 |