The appellant appealed reassessments under the Excise Tax Act for unremitted GST and disallowed input tax credits related to modular buildings leased to a mining company to house its workers.
The Tax Court of Canada found that the supply of the rooms to the workers was an exempt supply because the workers occupied them free of charge.
Consequently, the appellant was deemed to have given possession of the buildings for the purpose of occupancy as a place of residence, triggering the self-supply rules.
The appeal was dismissed, confirming the GST liability and the disallowance of the input tax credits.
