News and Insights

CRA Revises GST/HST Memorandum on Exported Tangible Personal Property

Tax Development Aug 27, 2014

In August 2014, the Canada Revenue Agency (“CRA”) issued a revised version of GST/HST Memorandum 4-5-2, Exports – Tangible Personal Property explaining the zero-rating provisions included in Part V of Schedule VI of the Excise Tax Act (“ETA”).  The additional information equates to approximately two extra pages.

Most of the added information pertains to the zero-rating provision for continuous transmission commodities.  The previous version of this memorandum did not include any information on the export of commodities.  In contrast, much of the information concerning export trading houses and the certificate program has been removed.  In its place, the CRA offers a phone number to call for further information regarding the program.

Some areas provide further insight into the CRA’s interpretation of certain terms and conditions that are found in the zero-rating provisions.  For example, while the terms “processed” and “altered” are not defined in the ETA, an interpretation and examples of what might constitute processing or altering, and what does not, have been included for the benefit of those trying to determine if their supplies qualify for zero-rating.

The layout of the memorandum has also changed, with an added section of relevant definitions and the illustrative examples have now been numbered.