Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada.
GST/HST Rulings Directorate
5th floor, Tower A, Place de Ville
320 Queen Street
Ottawa ON K1A 0L5
[Client Address]
Case Number: 206997a
Dear [Client]:
Subject: GST/HST ruling
Supply of logistics and fulfillment services
We have reviewed our letter dated March 18, 2021, under case number 206997, concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to a supply of logistics and fulfillment services. In the interest of accuracy and clarity, we wish to revoke our earlier letter. This amendment replaces and supersedes the original letter and is effective as of the date of this letter. We apologize for any inconvenience this may cause, as well as for the delay in this response.
The HST applies in the participating provinces at the following rates: 13% in Ontario; 14% in Nova Scotia; and 15% in New Brunswick, Newfoundland and Labrador and Prince Edward Island. The GST applies in the rest of Canada at the rate of 5%.
All legislative references are to the Excise Tax Act (ETA) unless otherwise specified.
STATEMENT OF FACTS
Based on […] supplementary documents […] and our telephone conversations, we understand the following:
1. […](CanCo) is a logistics company with headquarters in […][Province X] and it is registered for GST/HST purposes. CanCo has warehouses in [Province X], […][Province Y] and […][Province Z].
2. CanCo […] provides logistics and fulfillment services to various enterprises.
3. CanCo’s website […] specifies, […], that all business accepted and conducted by CanCo is subject to the “[…][terms and conditions that govern the business practices of logistics service providers in Canada]” […].
[…]
5. NRCo, a non-resident person that is not registered for the GST/HST, operates a logistics company outside Canada and provides courier, freight forwarding and logistics services to various enterprises.
6. NonResCo, a non-resident person that is not registered for the GST/HST and does not carry on any business in Canada, supplies goods […] by way of sale on a worldwide basis, including in Canada.
7. NonResCo manufactures or subcontracts for the manufacture of the goods outside Canada for subsequent export worldwide, including to Canada.
8. NonResCo operates a website through which it makes online sales of the goods that it delivers or makes available in Canada to purchasers who are not registered for the GST/HST (“Purchasers”).
9. NonResCo hired NRCo to act as its agent and representative with respect to the logistics, warehousing and fulfillment of goods sold to Purchasers in Canada.
10. In […][date], NRCo, acting as agent for NonResCo, hired CanCo to provide logistics, warehousing and fulfillment services with respect to NonResCo’s goods that are sold to Purchasers in Canada (“logistics agreement”). No written version of the logistics agreement between CanCo and NRCo was presented to us for review.
11. CanCo carries out its duties under the logistics agreement as an independent contractor and does not act as an agent for either NRCo or NonResCo.
12. NonResCo, or its agent, arranges for the transportation of CanCo’s goods from their place of manufacture outside Canada to CanCo, named as the final consignee of the goods on the air waybill, at their warehouse in Canada (see sample air waybill reference number [#] described below).
13. CanCo is a licensed customs broker able to clear shipments of goods into Canada, arrange customs bonds and prepare all documentation required by the Canada Border Services Agency for goods to be cleared into Canada.
14. On importation of the goods, CanCo prepares all necessary documentation on behalf of NonResCo, owner of the goods and importer of record of the goods, to facilitate the Canadian customs release and pays all applicable duties on the imported goods in compliance with the Customs Act (“customs brokerage services”).
15. CanCo arranges for a third-party freight transportation service company to transport the goods, after their release from Customs, from the Canadian port of entry to CanCo’s warehouse.
16. CanCo provides warehouse and fulfillment services (“Logistics Services”) for NonResCo’s goods sold into Canada, in particular, by providing the following:
* When the goods arrive at CanCo’s warehouse, CanCo provides the following “warehousing” services:
-receives, counts and inspects inbound deliveries,
-stores the goods in its warehouse,
-if required, places the goods into secure class storage,
-enters a record of the goods into its warehouse inventory management system,
* Once NonResCo’s Purchasers place purchase orders for goods online through NonResCo’s website, CanCo provides the following “fulfillment” services:
-retrieves purchase order information from NonResCo and enters it into own warehouse inventory management system,
-picks, packs and labels orders from NonResCo’s inventory according to the weekly recap (purchase order summary) of online orders,
-dispatches (ships) the orders (i.e. arranges with a third-party carrier to ship the goods to the Purchasers) via the most appropriate shipping method, for example by UPS courier, and
-tracks the shipments through to receipt by NonResCo’s Purchasers.
17. CanCo specifies that the order fulfillment services cannot be acquired without also purchasing the warehousing services.
18. CanCo issues a monthly invoice to NRCo for the provision of Logistics Services and other associated services whereby each element is separately itemized as follows:
* Customs brokerage fees/B3 fees
* Transportation (Cartage) fees
* Receiving/handling - charge per pallet in warehouse.
* Warehousing/Storage – charge per pallet in warehouse
* Picking/packing – charge per item
* Labelling – charge per label
* Shipping – charge per item shipped.
[…]
19. Sample air waybill labelled [#] in relation to the same transaction designates CanCo as the consignee of a shipment of goods transported by the carrier […] from […][city outside of Canada] to a Canadian port of entry ([…][city in Canada]) and the associated Canada Customs Coding Form (“B3”) indicates NonResCo is the importer of record of the goods.
20. At the outset of the arrangement with CanCo, NonResCo had an outstanding stock of inventory (1 pallet of goods) located in the warehouse of a previous logistics services provider in Canada. Following NRCo’s decision to change fulfillment partners and hire CanCo instead […][date], CanCo arranged for a carrier to transfer all of the existing inventory from this third-party warehouse to their own warehouse for the purpose of providing Logistics Services on the goods. […].
RULING REQUESTED
You would like to know how the GST/HST applies to:
1) CanCo’s services related to the one-time movement of NonResCo’s existing inventory from a third-party warehouse location in Canada to CanCo’s warehouse in Canada;
2) CanCo’s ongoing supply of Logistics Services;
3) CanCo’s ongoing supply of customs brokerage services; and
4) CanCo’s ongoing supply of services related to the movement of goods from a Canadian port of entry to its own warehouse in Canada.
RULING GIVEN
Based on the facts set out above, we rule that, for supplies made before July 1, 2021,
1) the supply in the […][date] of a service related to the movement of NonResCo’s outstanding inventory of goods held at a third-party warehouse in Canada to CanCo’s warehouse is a taxable supply on which CanCo must charge and collect GST/HST at the applicable rate;
2) the supply of Logistics Services will result in the application of the drop-shipment rule, such that:
a) CanCo must charge and collect GST/HST at the applicable rate on the fair market value of NonResCo’s goods, and
b) CanCo must charge and collect GST/HST at the applicable rate on their supply of the Logistics Services;
3) the supply of customs brokerage services is zero-rated; and
4) the supply of services related to the movement of goods from a Canadian port of entry to CanCo’s warehouse in Canada is zero-rated provided CanCo maintains documentary evidence satisfactory to the Minister that the services are part of a continuous freight movement from an origin outside Canada to a destination in Canada.
As noted in GST/HST Memorandum 1.4, Excise and GST/HST Rulings and Interpretations Service, a ruling provides the Canada Revenue Agency's (CRA) position on specific provisions of the legislation as these relate to a clearly defined fact situation of a particular person, and where all of the relevant facts and supporting documentation have been presented in writing.
For supplies made on or after July 1, 2021, we are unable to provide a ruling in respect of requests 2, 3 and 4 since the facts are insufficient to enable us to determine the application of the digital economy rules. The INTERPRETATION section below describes the digital economy rules and explains how they may apply in this case.
The supply referenced by the facts in the first ruling request occur only once, in 2019; accordingly, it is unnecessary to provide a corresponding ruling for the period after July 1, 2021 since no such supply occurs after that date.
EXPLANATION
Single vs multiple supplies
CanCo provides a number of services to NRCo in the context of their logistics agreement, including the Logistics Services (composed of the warehouse and fulfillment services), the customs brokerage services, and the services related to the movement of goods from a port of entry in Canada to CanCo’s warehouse in Canada. Where a transaction consists of several elements which are provided together, one must determine whether they constitute a single supply of property or services, or whether they retain their identities as separate supplies.
If it is determined that a single supply is being provided by a person, then the tax status will generally be based on the provisions of the ETA that pertain to the predominant element of the supply. If it is determined that multiple supplies are being provided by a person, it is necessary to determine if any of the elements are incidental supplies.
As discussed in policy statement P-077R2, Single and Multiple Supplies, the CRA considers that two or more elements are part of a single supply when the elements are integral, interdependent components that must be supplied together. Conversely, multiple supplies occur when one or more of the elements can sensibly or realistically be broken out.
To establish the correlation between several distinct elements, these need to be examined in the overall context of the recipient’s particular needs and the intent of the parties to the transaction, and not in isolation. For several separate elements to be considered to form a single supply, it must be the case that no one element, supplied on its own, would satisfy the recipient’s needs in that particular case.
Although in other contexts, each element of the supply could viably be supplied separately, the single/multiple supply analysis must be confined to the circumstances of the particular transaction at hand, rather than referring to other possible transactions containing the same or similar elements. For the purposes of the single/multiple supply analysis, it does not matter if the value of the consideration of all components of the supply is shown as a single amount or if each element of the supply is itemized separately.
The intent of the parties to the logistics agreement is for CanCo to operationalize the Canadian aspect of NonResCo’s online retail operations, such that NonResCo can make online sales of tangible personal property into Canada without having any presence in Canada and without having to conduct any operations in Canada themselves.
To this end, NonResCo, through its agent NRCo, hires CanCo to provide Logistics Services, described in Fact 16 as being composed of warehouse and fulfillment services, which effectively integrate the key components of its Canadian retail operations. It would not serve NonResCo’s purposes to receive only one or the other element of the Logistics Services because no single element, on its own, would satisfy NonResCo’s overall needs; rather, all of the components must be supplied together. Treating each element of the Logistics Services as separate supplies would not reflect the reality of the transaction between the parties. In addition, CanCo expressly stipulates that the fulfillment services cannot be purchased separately from the warehousing services.
Since the elements of the Logistics Services cannot realistically or sensibly be broken out, we view the various elements of the Logistics Services as integral components of a single supply of Logistics Services. It is also our view that the warehousing service is the predominant element of the supply of Logistics Services.
On the other hand, we view the customs brokerage services and the services related to the movement of goods from the port of entry to CanCo’s warehouse as each being separate supplies and not forming part of the supply of Logistics Services. These two elements (brokerage services and movement of the goods) can realistically and sensibly be broken out from the supply of the Logistics Services and thus constitute separate supplies.
Incidental supplies
Based on the single/multiple supply guidance above, we consider the brokerage services and the services related to the movement of the goods from a port of entry to CanCo’s warehouse to be separate and distinct from the supply of Logistics Services, but the question arises whether they may be considered incidental to it. On the topic of incidental supplies, section 138 provides that where
(a) a particular property or service is supplied together with any other property or service for a single consideration, and
(b) it may reasonably be regarded that the provision of the other property or service is incidental to the provision of the particular property or service,
the other property or service shall be deemed to form part of the particular property or service so supplied.
The brokerage services and the Logistics Services are not provided for a single consideration. Accordingly, the supply of brokerage services would not be considered incidental to the supply of Logistics Services and would not form part of that supply.
Similarly, the supply of services related to the continuous movement of the goods from the port of entry to CanCo’s warehouse would not be incidental to the supply of Logistics Services or brokerage services.
For further information, you may refer to GST/HST Policy Statements P-077R2, Single and Multiple Supplies, P-159R-1, Meaning of the Phrase Reasonably Regarded as Incidental, and P-160R, Meaning of the Phrase - Where a Particular Property or Service is Supplied Together with any Other Property or Service.
Supplies made before July 1, 2021
One-time movement of goods from a warehouse in Canada to another warehouse in Canada
Generally, most supplies of services that are made in Canada are taxable supplies subject to the GST/HST unless the supply is specifically identified as exempt. Taxable supplies include zero-rated supplies (taxable at 0%) that are listed in Schedule VI to the ETA. Exempt supplies are not subject to the GST/HST and are listed in Schedule V to the ETA.
Section 142 determines whether a supply of a service is deemed to be made in Canada. Paragraph 142(1)(g) deems a supply of a service to be made in Canada if the service is, or is to be, performed in whole or in part in Canada.
The transfer […][date] of NonResCo’s outstanding inventory from a third-party warehouse in Canada to CanCo’s warehouse is a service in relation to the domestic transportation of goods that were transferred and already in Canada and not part of a continuous freight movement from an origin outside Canada. Accordingly, this constitutes a taxable supply made in Canada of either a freight transportation service (“carrier”) or a service of acting as an agent, such as a “freight forwarder,” in respect of such transportation.
The statement of facts is insufficient to enable us to determine whether CanCo is providing services related to the transfer of the goods as a carrier or as a freight forwarder. But in either case, there are no provisions to exempt or zero-rate such a supply and it would therefore be a taxable supply on which CanCo must charge and collect GST/HST at the applicable rate.
Logistics Services
While supplies of services that are performed in whole or in part in Canada are generally considered to be supplies made in Canada under paragraph 142(1)(g), it should be noted that section 179, commonly referred to as the “drop-shipment rule,” provides an exception to this rule in certain circumstances.
The drop-shipment rule applies, for example, where a registrant acquires physical possession of tangible personal property (TPP) for purposes of making a taxable supply in Canada of a commercial service in respect of the TPP to a non-resident person who is not registered for the GST/HST, and subsequently transfers physical possession of the TPP in Canada to another person or to the non-resident person.
Subsection 123(1) defines a commercial service in respect of TPP as any service in respect of the property other than (a) a service of shipping the property supplied by a carrier, (b) a financial service and (c) a service acquired for consumption, use or supply in the course of, or in connection with, the performance of a mining activity as defined in subsection 188.2(1). A carrier means a person who supplies a freight transportation service as defined in subsection 1(1) of Part VII of Schedule VI to the ETA.
CanCo acquires physical possession of NonResCo’s goods at their warehouse in Canada for the purpose of providing a commercial service (the Logistics Services) in respect of the goods and subsequently transfers physical possession of the goods to a Purchaser in Canada. In this case, the drop-shipment rule at subsection 179(1) applies with the following consequences.
Pursuant to paragraphs 179(1)(d) and (f), CanCo is deemed to have made a taxable supply of the goods to the non-resident person at their fair market value and the tax is payable on that supply at the applicable rate at the time when CanCo transfers physical possession of the goods to the Purchaser in Canada.
Pursuant to paragraph 179(1)(e), if the transfer of physical possession of the goods to the Purchaser occurs at a place in a participating province, the supply is deemed to have been made in that province.
Pursuant to paragraph 179(1)(g), the supply of the commercial service is deemed not to have been made by CanCo, except if the supply is a supply of a service of storing the goods. Since the predominant element of the Logistics Services is the storage of the goods, 179(1)(g) would be inapplicable in this case. As a result, tax will also be payable on CanCo’s supply of the Logistics Services at the applicable rate.
CanCo usually acquires physical possession of the goods at its warehouse in Canada following their arrival from an inbound international shipment and subsequent transportation by carrier from the port of entry to CanCo’s warehouse. In a single instance in […][year], CanCo acquired physical possession of the goods at its warehouse in Canada after their transfer, by carrier, from a previous location at a third-party’s warehouse in Canada. In both cases, CanCo takes physical possession of the goods upon their arrival at its warehouse in Canada and, once CanCo transfers physical possession of the goods to a Purchaser in Canada, the drop shipment rule takes effect and applies in the manner just described. Thus, the application of the tax to the supply of Logistics Services remains the same in both cases regardless of the origin of the goods.
Customs brokerage services
Section 5 of Part V of Schedule VI to the ETA zero-rates a supply made to a non-resident person of a service of acting as an agent of that person, to the extent that the service is in respect of
(a) a supply to that person that is included in any other section of this Part; or
(b) a supply made outside Canada by or to that person.
For purposes of Part V of Schedule VI to the ETA, CRA considers a person working with a non-resident to be providing the services of an agent based on general legal principles. An agent includes a person who is authorized to bring another party for whom the person acts (i.e., the principal) into contractual relations with third parties. Whether a person will be considered an agent of another person is a question of fact.
The onus is on the parties involved in any transaction to determine whether an agency relationship exists. However, customs brokers are generally considered agents for purposes of section 5 of Part V of Schedule VI to the ETA with respect to their customs brokerage services. A supply of a customs brokerage service made to a non-resident person by an agent, such as a customs broker, may be zero-rated where the conditions of section 5 are met.
While supplies of goods by way of sale that are delivered or made available to the recipient in Canada are generally considered to be supplies made in Canada under paragraph 142(1)(a), it should be noted that subsection 143(1) provides an exception to this rule for supplies made in Canada by a non-resident person who does not carry on a business in Canada and is not registered for the GST/HST under subdivision d of Division V.
Specifically, where a non-resident person makes a supply of goods by way of sale that are delivered or made available to a recipient in Canada, but they are neither carrying on business in Canada nor registered for purposes of the GST/HST under subdivision d of Division V, their supplies will be deemed by subsection 143(1) to be made outside Canada. As a result, if all of the other conditions of paragraph 5(b) of Part V of Schedule VI to the ETA are met, the supply of customs brokerage services made by CanCo to the non-resident person would be zero-rated.
Movement of goods from a port of entry in Canada to CanCo’s warehouse
A supply of a freight transportation service from a place in Canada to another place in Canada is zero-rated under section 10 of Part VII of Schedule VI to the ETA if:
* it is part of a continuous freight movement from an origin outside Canada to a destination in Canada; and
* the supplier of the service maintains documentary evidence satisfactory to the Minister that the service is part of a continuous freight movement from an origin outside Canada to a destination in Canada as specified by the shipper. Satisfactory evidence includes a copy of an air waybill showing the origin and destination of a shipment.
Subsection 1(1) of Part VII of Schedule VI to the ETA defines a freight transportation service, in part, as the service of transporting TPP (for example, domestic trucking and handling), including a service of delivering mail, and any other property or service supplied to the recipient of the particular service by the person who supplies the particular service where the other property or service is part of or incidental to the particular service, even if there is a separate charge for the other property or service.
A continuous freight movement is defined under subsection 1(1) of Part VII of Schedule VI to the ETA as the transportation of tangible personal property by one or more carriers to a destination specified by the shipper of the property, where all freight transportation services supplied by the carriers are supplied as a consequence of instructions given by the shipper of the property.
A destination, in respect of a continuous freight movement of property, is defined under subsection 1(1) of Part VII of Schedule VI to the ETA as a place specified by the shipper of the property where possession of the property is transferred to the person to whom the property is consigned or addressed by the shipper.
A shipper of tangible personal property is defined under subsection 1(1) of Part VII of Schedule VI to the ETA as the person who, in respect of a continuous freight movement or a continuous outbound freight movement, transfers possession of the property being shipped to a carrier at the origin of the freight movement and, for greater certainty, does not include a person who is a carrier of the property to which the freight movement relates.
As evidenced by the sample air waybill [#], the shipper transfers possession of the goods to a carrier at a location overseas for shipment to CanCo, designated as consignee of the goods, at their premises in Canada. The first carrier transports the goods from a place of origin outside Canada ([city outside of Canada]) to a Canadian port of entry ([city in Canada]) and a second carrier transports the goods from the Canadian port of entry to CanCo’s warehouse. This constitutes a continuous freight movement from an origin outside Canada to a destination in Canada. The continuous freight movement ends when the goods arrive at the destination specified by the shipper of the property, in this case CanCo’s premises in Canada.
The facts are insufficient to enable us to determine whether CanCo is providing services related to the movement of the goods as a carrier or as a freight forwarder. However, in either case, CanCo’s supply of services related to the movement of the goods would be zero-rated, for the reasons we explain below.
If CanCo assumed liability as a supplier of a freight transportation service, the supply would be a freight transportation service and would be zero-rated under section 10 of Part VII of Schedule VI to the ETA, provided CanCo maintains documentary evidence satisfactory to the Minister that the services are part of a continuous freight movement from an origin outside Canada to a destination in Canada.
If CanCo acted as a freight forwarder and arranged transportation of the goods for NonResCo from the port of entry to CanCo’s warehouse it would be making a supply of a service of acting as an agent. A supply of a service of acting as an agent for a non-resident person who is not registered under Subdivision d of Division V at the time the supply is made, to the extent that the service is in respect of a supply to that person of a freight transportation service that is included in section 10, would be zero-rated under section 12 of Part VII of Schedule VI to the ETA.
For additional information, please refer to GST/HST Memorandum 28.2, Freight Transportation Services.
INTERPRETATION
Supplies made on or after July 1, 2021
Digital Economy Provisions
The digital economy provisions under Subdivision E of Division II of Part IX of the ETA are in effect as of July 1, 2021. Digital economy businesses, including non-resident suppliers, may have new potential GST/HST obligations under these provisions. This means these businesses may have new obligations, including registering, charging, collecting and reporting the GST/HST.
GST/HST registration requirements under the digital economy provisions
Under the digital economy provisions and more specifically pursuant to subsection 211.22(2), a non-resident person that does not make supplies in the course of a business carried on in Canada is required to be registered under Subdivision d of Division V (the regular GST/HST registration provisions) if their threshold amount exceeds $30,000 in qualifying tangible personal property supplies made to specified recipients in a twelve-month period beginning on or after July 1, 2021.
A qualifying tangible personal property supply is defined in subsection 211.1(1) as “a supply made by way of sale of TPP that is, under the agreement for the supply, to be delivered or made available to the recipient in Canada, other than
(a) an exempt or zero-rated supply;
(b) a supply of TPP sent by mail or courier to the recipient at an address in Canada from an address outside Canada by the supplier or by another person acting on behalf of the supplier, if the supplier maintains evidence satisfactory to the Minister that the property was so sent;
(c) a supply that is deemed under subsection 180.1(2) to have been made outside Canada; and
(d) a prescribed supply.”
A specified recipient in respect of a supply of property is defined in subsection 211.22(1) to be “a person (other than a non-resident person that is not a consumer of the property) that is the recipient of the supply and that is not registered under Subdivision d of Division V.”
Where a non-resident client of CanCo is required to register under subsection 211.22(2), the drop shipment rules would no longer apply to require CanCo to charge and collect the GST/HST on the fair market value of the non-resident’s goods. Instead, the GST/HST would only be required to be collected on CanCo’s supply of the Logistics Services to the registered non-resident client.
CanCo’s supplies
Starting July 1, 2021, the application of the tax on CanCo’s supply of Logistics Services, customs brokerage services and services related to the movement of goods from a Canadian port of entry to CanCo’s warehouse will depend on whether the digital economy rules apply and whether NonResCo is registered for the GST/HST under Subdivision d of Division V.
For example, if NonResCo is registered for the GST/HST under Subdivision d of Division V in accordance with the digital economy rules, then the drop-shipment rules would no longer apply to CanCo’s supply of Logistics Services. The supply of Logistics Services by CanCo remains a taxable supply made in Canada, pursuant to paragraph 142(1)(g), on which CanCo must charge and collect GST/HST at the applicable rate. Paragraphs 179(1)(d) and (f) would no longer apply to deem a supply of the goods to be made by CanCo at their fair market value and no tax would be charged and collected on this deemed supply by CanCo. The non-resident person may have its own tax obligations under the digital economy rules with respect to its supplies of goods to the Purchasers.
Likewise, if NonResCo is registered for the GST/HST under Subdivision d of Division V, the condition at paragraph 143(1)(b) is met with the result that NonResCo would no longer deemed to be making supplies of goods outside Canada. Since NonResCo’s supplies of goods are deemed to be made in Canada under paragraph 142(1)(a), paragraph 5(b) of Part V of Schedule VI to the ETA is no longer satisfied and the supply of brokerage services by CanCo to NonResCo would no longer be zero-rated under paragraph 5(b). The supply of brokerage services by CanCo would then be a taxable supply on which CanCo would have to charge and collect GST/HST at the applicable rate.
Finally, where CanCo is making a supply of a “freight transportation service” from the port of entry to CanCo’s warehouse, that supply would not be impacted by the new digital economy rules. A freight transportation service would still be zero-rated under section 10 of Part VII of Schedule VI to the ETA if all of the conditions of that provision are satisfied.
However, where CanCo is making a supply of a service of acting as an agent for a non-resident person in respect of a transportation service (“freight forwarder”), that supply would no longer be zero-rated if the condition under section 12 of Part VII of Schedule VI to the ETA, that the non-resident person not be registered under Subdivision d of Division V, is no longer satisfied. That is, if the non-resident person is registered for the GST/HST under Subdivision d of Division V, then CanCo would be required to charge and collect GST/HST at the applicable rate on its supply of freight forwarder services with respect to the movement of the goods.
DISCLAIMER
In accordance with the qualifications and guidelines set out in GST/HST Memorandum 1-4, Excise and GST/HST Rulings and Interpretations Service, the CRA is bound by the rulings given in this letter provided that: none of the issues discussed in the rulings are currently under audit, objection, or appeal; no future changes to the ETA, regulations or the CRA’s interpretative policy affect its validity; and all relevant facts and transactions have been fully and accurately disclosed. The interpretation given in this letter is not a ruling and does not bind the CRA with respect to a particular situation. Future changes to the ETA, regulations, or the CRA’s interpretative policy could affect the interpretation provided herein.
CONTACT
If you require clarification with respect to any of the issues discussed in this letter, please call me directly at 819-271-7136.
Should you have additional questions on the interpretation and application of the GST/HST, please contact a GST/HST Rulings officer at 1-800-959-8287.
Sincerely,
Megan MacDonald
Rulings Officer
Border Issues Unit 2
General Operations and Border Issues Division
GST/HST Rulings Directorate
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