An organization operating treatment and support centres for children sought a declaration that two properties were exempt from municipal property taxation under s. 3(1)6.1 of the Assessment Act.
The respondents argued that the exemption applied only to facilities formally designated by the Ministry of Community and Social Services as “Children’s Treatment Centers.” The court held that the legislation contained no definition requiring such designation and that the ordinary meaning of a children’s treatment centre governed.
Based on the evidence that the facilities primarily provided treatment to children and received provincial funding, the properties qualified for the exemption.
A declaration of tax exemption was granted.
