Précis: The taxpayer, a private corporation, operated Highway 407 in Ontario under a public-private partnership arrangement. Policing for the Highway was provided by the Ontario Provincial Police (“OPP”) and was billed by the OPP to the taxpayer. The taxpayer took the position that the policing was the supply of a “municipal service” and therefore an exempt supply. CRA took that position that, since the policing was provided by the province and not a municipal entity, the service was taxable.
407 ETR Concession Company Limited v. R. - TCC: Policing Highway 407 by OPP an exempt supplyREAD MORE »