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Subsection 225.2(2)

Administrative Policy

B-107 "Investment Plans (Including Segregated Funds of an Insurer) and the HST" April 2013

9. Specified attribution method formula

An SLFI [selected listed financial institution] uses the SAM [specified attribution method] formula to calculate its liability for the provincial part of the HST for a participating province. If the amount calculated using the SAM formula for the provincial part of the HST for a participating province for a reporting period of an SLFI is less than the provincial part of the HST for the province that is actually paid or payable by the SLFI in the period (as a result of the application of the general place of supply rules to supplies made to the SLFI), the SLFI will make an adjustment when calculating its net tax that will either reduce its net tax or result in a refund. Conversely, if the amount determined under the SAM formula is more than the actual provincial part of the HST for the province that is paid or payable by the SLFI in the period, the SLFI will have an additional liability for the provincial part of the HST and make an adjustment when calculating its net tax that will increase its net tax.

Provincial ITCs

As SLFIs use the SAM formula to calculate their liability for the provincial part of the HST for a participating province, they are generally not required to track and allocate the extent of consumption or use of each property or service acquired in the participating provinces in order to claim input tax credits (ITCs) related to the applicable provincial part of the HST (either 7%, 8%, or 10% depending on the participating province), nor are they required to self-assess and account for tax on inputs acquired in a non-participating province for consumption, use or supply in a participating province.

Specifically, subsection 169(3) of the Act restricts an SLFI's ability to claim an ITC in respect of the provincial part of the HST... .

Modified SAM for stratified/real time investment plans

An SLFI investment plan uses the SAM formula in subsection 225.2(2) to calculate its liability for the provincial part of the HST. However, where the investment plan

  • is a non-stratified investment plan with a real-time calculation method election in effect for a reporting period in a fiscal year, or
  • is a stratified investment plan,

these investment plans would use an adapted SAM formula provided by section 51 [now s. 48] of the draft SLFI Regulations


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