The appellant facilitated bariatric surgeries for Canadians at a hospital in Mexico.
The Minister reassessed the appellant for uncollected GST/HST on fees collected from patients and remitted to the Mexican hospital.
The Tax Court allowed the appeal, finding that the appellant acted as an agent or conduit for the Mexican hospital in collecting and remitting those fees, meaning the fees did not form part of the appellant's consideration for its own services.
The appellant was also entitled to input tax credits for travel arrangements made in the course of its commercial activities.
