Section 163

The appellant, a registrant, provided zero-rated vacation packages to customers who had also paid a non-refundable "membership fee" in the previous twelve months. In finding that this fee was part of the consideration for the zero-rated vacation package, Dussault TCJ. noted (at p. 28-10) that "if one concludes that there is a supply separate from the supply of the vacation package it must be of 'a useful article or service'" and that, here, the alleged benefits attached to membership "represent nothing more than promotional literature used by Club Med for marketing its vacation packages at Club villages abroad" (p. 28-11).