November 21st, 2023
Insurance Brokers/Financial Institutions –
Northbridge Commercial Insurance Corporation v. King overturned the Tax Court of Canada’s decision. This ruling allowed a financial institution that issued insurance policies for trucking companies operating in Canada and the U.S. to claim some ITCs on some of its expenses, since the registrant made certain zero-rated supplies. The Federal Court of Appeal thus determined that the portions of the insurance policies that related to accidents outside Canada qualified as zero-rated supplies, since they were to be treated as supplies of exported services, zero-rated under Part 9, section 2 of Schedule VI to the ETA. The determination of which part of the insurance policies related to exported supplies of services needed to be assessed on the basis of several criteria.
Be sure to call our specialists to figure out if a claim might now be available for you!
