- Insurance policies are zero-rated to the extent they cover risks ordinarily situated outside Canada.
- The taxpayer (Northbridge) claimed input tax credits for such zero-rated supplies.
- The FCA ruled that input tax credits apply to general head office and overhead costs for all policies, not just specific ones.
- The TCC had not determined the proper allocation method for these costs, so the case was sent back for further analysis.
- The parties later agreed on the amount of input tax credits, and a consent judgment was issued.
Source: mccarthy.ca
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.
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