The appellant, Zomaron Inc., appealed GST/HST assessments on fees it received from payment processors (Elavon and First Data) for its services in negotiating and securing merchant commitments for credit and debit card processing.
The Minister assessed the fees as taxable supplies.
The Tax Court of Canada allowed the appeal, finding that Zomaron provided a single compound supply whose predominant element was acting as a financial intermediary 'arranging for' a financial service within the meaning of paragraph (l) of the definition of 'financial service' in subsection 123(1) of the Excise Tax Act.
The services were therefore exempt from GST/HST.
