NORTHBRIDGE COMMERCIAL INSURANCE CORPORATION v. HIS MAJESTY THE KING
NORTHBRIDGE COMMERCIAL INSURANCE CORPORATION
HIS MAJESTY THE KING
Law Firm / Organization
Department of Justice Canada

Background:

  1. Insurance Policies: Northbridge issued insurance policies to trucking companies operating in Canada and the United States, covering accidents and other insurable events.
  2. 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.
  3. 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??.
Federal Court of Appeal
A-2-21
Taxation
Appellant
04 January 2021