- MELP was found to be acting as an agent for a Mexican company, providing services to Canadian patients undergoing surgery in Mexico
- MELP was not subject to GST/HST on the portion of patient fees collected as agent for the Mexican company
- However, MELP’s own fees were not zero-rated as they were partly performed in Canada
- The Tax Court of Canada found that services performed by MELP on behalf of the Mexican company were in significant part performed in Canada
- This meant that the place of supply was deemed to be in Canada, contrary to the requirements for zero-rated agency services
Source: taxinterpretations.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
