CRA rules that a federally incorporated charity is resident for HST rebate purposes where its office is

ETA s. 132.1(3) and s. 2(2) of the New Harmonized Value-added Tax System Regulations, No. 2 provide that a charity is deemed to have a permanent establishment in a province if a place in that province would be a permanent establishment for income tax purposes if the charity were a corporation and its activities were a business for income tax purposes. Although this test could give rise to metaphysical difficulties, CRA had no difficulty in ruling that a federally-incorporated charity which managed its activities out of a single office in “Province 1” was resident for HST rebate purposes in Province 1.

Neal Armstrong. Summary of 23 June 2015 Interpretation 144489 under ETA s. 132.1(3).