Insurance Policies: Northbridge issued insurance policies to trucking companies operating in Canada and the United States, covering accidents and other insurable events.
Claim for Input Tax Credits (ITCs): Northbridge claimed ITCs for a portion of the GST/HST paid on its general head office and overhead costs, asserting that it was making zero-rated supplies under these policies.
Legal Basis: Under Section 2 of Part IX of Schedule VI of the Excise Tax Act, a financial service related to any particular policy issued by a financial institution is considered a zero-rated supply.
Legal Proceedings:
Northbridge's claim for ITCs was the subject of this appeal, focusing on whether the policies qualified as zero-rated supplies under the Excise Tax Act??.