The appellant, a dentist, claimed input tax credits (ITCs) for HST paid in respect of his dental practice, arguing that he made single, zero-rated supplies of artificial teeth to his patients.
The Minister assessed the appellant, disallowing the ITCs on the basis that the appellant made multiple supplies, including exempt dental services.
The Tax Court of Canada found that the appellant made a single supply to each patient, but that the predominant element of the supply was the provision of exempt dental services, not zero-rated artificial teeth.
As the business involved making exempt supplies, it was not a commercial activity, and the appellant was not entitled to the ITCs.
The appeals were dismissed.
