The Canada Revenue Agency ("CRA") has recently issued GST/HST Technical Information Bulletin B-109, “Application of the GST/HST to the Practice of Naturopathic Doctors” which explains how the GST/HST applies to goods and services supplied by a naturopathic doctor in a practise of naturopathy.
This comprehensive publication outlines the conditions under which an exemption from GST/HST may apply for naturopathic services, which include:
- the naturopathic service provided must be within the scope of practice for a naturopathic doctor;
- the naturopathic service is rendered to an individual by a practitioner;
- the naturopathic service is a qualifying health care supply; and
- the naturopathic service is not a supply of a cosmetic service.
Prior to February 11, 2014, naturopathic doctors were not included as exempt health care practitioners under Schedule V, Part II of the Excise Tax Act (“ETA”). However, effective this date, the ETA was amended to include naturopathic doctors, and subject to meeting specific criteria, the GST/HST exemption, in section 7 of this Part of the ETA, will now apply to naturopathic services rendered to an individual by a naturopathic doctor.
It is interesting to note that the CRA defines a qualifying health care supply to mean “a service supplied by a naturopathic doctor for the purpose of maintaining health; preventing disease; treating, relieving or remediating an injury, illness, disorder or disability; assisting (other than financially) an individual in coping with an injury, illness, disorder or disability; or providing palliative health care.” Therefore if the service is not provided for one of these purposes (e.g., delivered to an insurance company for assessment purposes), the supply is not a qualifying health care supply.
The bulletin contains, among other topics, several examples to illustrate the application of the GST/HST exemption, the application of GST/HST under various practice types(e.g., sole proprietor, partnership, associate practitioner), as well as the GST/HST registration requirements for naturopathic doctors.