Zero-Rating of Insurance Policies Covering Foreign Risks: Northbridge v. The King, 2025 FCA 83

• 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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