Calculating the GST/HST on Tour Packages
GST/HST memorandum 27-1
September 2025
This version replaces the one dated June 2009. This memorandum has been updated to add definitions and significant terms related to tour packages. It also cancels and replaces GST/HST Memorandum 27-3, Foreign Convention and Tour Incentive Program – Rebate for Eligible Tour Packages and Accommodation Supplied as Part of Eligible Tour Packages.
This memorandum explains that suppliers that sell tour packages are required to identify the various elements of the package to determine the amount of the GST/HST, if any, that they must collect and the rate of tax that applies.
Except as otherwise noted, all statutory references in this publication are to the provisions of the Excise Tax Act (ETA). The information in this publication does not replace the law found in the ETA and its regulations.
If this information does not completely address your particular situation, you may wish to refer to the ETA or relevant regulation, or call GST/HST Rulings at 1‑800‑959‑8287 for additional information. If you require certainty with respect to any particular GST/HST matter, you may request a ruling. GST/HST Memorandum 1-4, Excise and GST/HST Rulings and Interpretations Service, explains how to obtain a ruling or an interpretation and lists the GST/HST rulings centres.
If you are located in Quebec and wish to request a ruling related to the GST/HST, please call Revenu Québec at 1‑800‑567‑4692. You may also visit the Revenu Québec website at revenuquebec.ca to obtain general information.
For listed financial institutions that are selected listed financial institutions (SLFIs) for GST/HST or Quebec sales tax (QST) purposes or both, whether or not they are located in Quebec, the CRA administers the GST/HST and the QST. If you wish to make a technical GST/HST or QST enquiry related to SLFIs, please call 1‑855‑666‑5166.
GST/HST rates
Reference in this publication is made to supplies that are subject to the GST or the HST. The GST/HST rates are those that were in effect at the time of publishing. For the list of all applicable GST/HST rates (current and historic), go to GST/HST calculator (and rates).
If you are uncertain as to whether a supply is made in a participating province, refer to GST/HST Memorandum 3-3-2, Place of Supply in a Province – Overview.
Table of contents
- General
- Definitions and significant terms
- Characterizing the supply
- Determining the consideration for the portions of a tour package
- Taxable percentage of the relevant portion
- Documentation
- Insurance
- Appendix 1 – Application of the GST/HST to a tour package
- Appendix 2 – Certificate of zero-rated entitlement
General
1. Generally, suppliers such as tour operators purchase passenger transportation services, short-term and/or camping accommodation, sightseeing excursions, and other property and/or services which they assemble into tour packages and supply for an all-inclusive price. Suppliers that sell tour packages in Canada must prorate the selling price of a package based on the value of the taxable and non-taxable property and services included in the package to determine the amount of the GST/HST that they must charge.
2. There are rules under section 163 that must be applied when prorating the selling price of a tour package based on the value of the taxable property and services included in the package. Generally, taxable property and services are the property and services included in a tour package that, if supplied separately and not as part of a package, would be taxable for GST/HST purposes. Before applying these rules related to prorating (which are explained beginning at paragraph 37 of this memorandum), the supplier must ensure that what is being supplied is a tour package.
Definitions and significant terms
3. Under subsection 163(3), tour package means "a combination of two or more services, or of property and services, that includes transportation services, accommodation, a right to use a campground or trailer park, or guide or interpreter services, where the property and services are supplied together for an all-inclusive price".
4. The meaning of a tour package under the ETA could result in a single supply that is a combination of two or more services, or of property and services, being considered a tour package for GST/HST purposes even though the package may not fit the common perception of a tour package. The reverse is also possible; that is, something that may appear to be a tour package may not, in fact, be a tour package for GST/HST purposes.
Example 1
A registrant supplies foreign tourists with a package that includes a meal at a restaurant, a ticket to a sporting event, and the services of an interpreter. The property and services are supplied together for an all-inclusive price.
Although this package may not fit the common perception of a tour package, it is a tour package for GST/HST purposes.
5. The term all-inclusive price is not defined in the ETA but is generally understood to mean a single price for all property and services supplied together in a package. In the tourism industry, prices for certain items are sometimes listed separately on the invoice for information purposes. Even where this is the case, in some circumstances, the package may still be considered to be supplied for an all-inclusive price. The price of accommodation included in a tour package may be listed separately on an invoice to inform the purchaser of the amount on which the applicable provincial sales tax is calculated. This package is supplied for an all-inclusive price because the price of accommodation is listed separately only for information purposes.
6. A package is not supplied for an all-inclusive price when the reason some or all of the elements of the package are listed separately on the invoice is because some or all of the elements are supplied separately or supplied on behalf of other persons.
Example 2
A tour operator supplies short-term accommodation, meals, and a guided tour of the city for one price. Travellers have the option of purchasing tickets for two plays for an additional price. If purchased, the tickets are added to the invoice as a separate purchase.
The tickets purchased separately are not part of the package. The other elements are part of a package supplied for an all-inclusive price.
7. Under subsection 123(1), property means "any property, whether real or personal, movable or immovable, tangible or intangible, corporeal or incorporeal, and includes a right or interest of any kind, a share and a chose in action, but does not include money".
8. Examples of property are:
- short-term and camping accommodation
- meals
- a right to enter or attend an event (such as tickets to a show or hockey game)
- a car supplied by way of rental
- ski equipment supplied by way of rental
- a right to use real property as evidenced by ski lift tickets or park passes
- a right to use a golf course
9. Under subsection 123(1), service means "anything other than
- property,
- money, and
- anything that is supplied to an employer by a person who is or agrees to become an employee of the employer in the course of or in relation to the office or employment of that person".
10. Examples of services are:
- the services of a guide or interpreter
- transportation services (such as bus tours and air transportation)
- sightseeing excursions
- ski lessons
11. Under subsection 123(1), short-term accommodation means "a residential complex or a residential unit that is supplied to a recipient by way of lease, licence or similar arrangement for the purpose of its occupancy by an individual as a place of residence or lodging, if the period throughout which the individual is given continuous occupancy of the complex or unit is less than one month and, for the purposes of section 252.4,
- includes any type of overnight shelter (other than shelter on a train, trailer, boat or structure that has means of, or is capable of being readily adapted for, self-propulsion) when supplied as part of a tour package (within the meaning assigned by subsection 163(3)) that also includes food and the services of a guide, and
- does not include a complex or unit when it
- is supplied to the recipient under a timeshare arrangement, or
- is included in that part of a tour package that is not the taxable portion of the tour package (within the meaning assigned to those expressions by subsection 163(3))".
12. Overnight or week-long accommodation in hotels and motels is considered to be short-term accommodation.
13. If the consideration for a supply of accommodation does not exceed $20 for each day of occupancy, the supply is exempt pursuant to paragraph 6(b) of Part I of Schedule V and is not considered short-term accommodation. It would be included in the non-taxable portion of a tour package.
14. Under section 252.4, sponsors and non-registered organizers of foreign conventions held in Canada are eligible for a rebate of the GST/HST paid in respect of the convention facility and related convention supplies. For more information, refer to GST/HST Memorandum 27-2, Conventions.
15. Participating province means a province that has harmonized its provincial sales tax with the GST to implement the HST. Participating provinces include New Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario, and Prince Edward Island, but do not include the Nova Scotia offshore area or the Newfoundland offshore area except to the extent that offshore activities, as defined in subsection 123(1), are carried on in that area.
16. Non-participating province means a province that is not a participating province, or another area in Canada that is outside the participating provinces.
17. As in any transaction, it is important to properly characterize what is being supplied to determine how the GST/HST applies to the particular transaction. As illustrated in Examples 3 to 7, one should not assume that every combination that includes elements such as passenger transportation services or accommodation is a tour package for GST/HST purposes. Appendix 1 outlines the steps that a supplier should follow when determining if the GST/HST applies to the supply of a tour package.
18. When a person combines two or more services, or property and services, the person must determine whether it is making a single supply or multiple supplies. The determination of whether a transaction consists of a single supply or multiple supplies is a determination of fact. GST/HST Policy Statement P-077R2, Single and Multiple Supplies, provides guidelines that will assist in making that determination.
Tour package
19. If it is determined that what is being supplied is a single supply, the next step is to determine if the supply is a supply of a tour package. Generally, a tour package is assembled by combining two or more services, or property and services. A tour package is a single supply for GST/HST purposes.
20. All combinations of two or more services, or of property and services, are not necessarily tour packages. The nature and purpose of the package being supplied has to be considered to determine whether it is a tour package or something else. If the overall purpose of a package is to provide a specialized service, it is not considered a tour package for GST/HST purposes. Examples of such packages include wellness packages, educational and counselling packages, children's overnight camps, and tournaments.
Wellness packages
21. Wellness packages, such as spa and yoga packages, have as their focus, services or treatments to be rendered by persons having specialized skills or expertise. Their purpose is to promote wellness by providing services or treatments, such as massages, spa treatments, yoga classes, or relaxation therapy. These packages may also include accommodation and access to resort facilities and services.
22. Wellness packages are not tour packages for GST/HST purposes. The extra elements, such as accommodation and meals, are simply furnished as a component of the overall wellness treatments.
Example 3
A stay at a wellness spa retreat in Canada that is supplied for an all-inclusive price consists of wellness treatments, spa treatments, healthy meals and snacks, yoga classes, access to the gym and saunas, and accommodation at the retreat.
This package is not a tour package for GST/HST purposes. Items such as meals, yoga classes, access to the gym and saunas, and accommodation are part of the wellness treatment.
Educational and counselling packages
23. Educational packages, such as immersion camps and training seminars, and packages offering counselling services, such as marriage encounter and rehabilitation programs, have as their focus, services to be supplied by professionals. The packages may also include meals, educational or reference materials, and accommodation.
24. An educational or counselling package is not a tour package for GST/HST purposes and is generally considered to be a single supply of professional services. The other elements of the package are furnished as a component of the overall professional service.
Example 4
A business in Canada supplies an all-inclusive package to international students, which consists of instruction in English as a second language, books, instructional materials, accommodation, three meals per day, and recreational activities.
The package is not a tour package for GST/HST purposes. This is a service of instructing individuals in English as a second language. The other items are part of the service of language instruction.
Example 5
A rehabilitation centre offers weekend clinics that consist of counselling services, books, videos, meals, and accommodation for an all-inclusive price.
The package is not a tour package for GST/HST purposes. The centre is offering counselling services. The other elements are part of the counselling service.
Children's overnight camps
25. Some commercial businesses and public sector bodies operate children's overnight camps involving supervision or instruction in recreational or athletic activities. Typically, the overnight camps are offered for an all-inclusive price. These overnight camps are not tour packages for GST/HST purposes.
Example 6
A stay at a children's overnight camp is supplied for an all-inclusive price. The camp's fee covers supervised camp activities, meals, laundry, field trips, a camp T-shirt, and supervised accommodation at the camp.
The overnight camp is not a tour package for GST/HST purposes. The supervised accommodation is part of the supervised activities.
Tournaments
26. Tournaments, such as a sports competition, are usually group packages designed to enable individuals to participate in a competition, or similar events. The purpose of these packages is to provide a right to participate in a tournament or an event. As a result, these packages are not tour packages for GST/HST purposes.
Example 7
A softball league association organizes a tournament to which non-resident athletes are invited. For an all-inclusive price, the association provides entry into the tournament, the venue, all officials, medals, a closing banquet, and an awards ceremony. It also arranges for transportation and accommodation for the participants.
The tournament is not a tour package for GST/HST purposes. The association is providing a right to participate in a tournament. The other elements are part of the right to participate in the tournament.
Fully Independent Travel tours and customized tour packages
27. Fully Independent Travel (F.I.T.) tours and customized tour packages are tour packages if they are sold for an all-inclusive price and they include a combination of two or more services, or of property and services.
28. For example, an F.I.T. tour that includes hotel accommodation in Canada and a flight sold together for an all-inclusive price by a single person is a tour package. However, an F.I.T. tour that includes hotel accommodation in Canada and a flight sold separately is not a tour package as it is not sold for an all-inclusive price (even if the accommodation and the flight are listed on the same invoice). In addition, an F.I.T. tour that contains hotel accommodation in Canada and a flight sold to the traveller by separate persons or by an agent acting on behalf of separate persons is not a tour package as these are two separate supplies. Refer to paragraph 18 of this memorandum for more information on single and multiple supplies. For more information on agents, refer to GST/HST Info Sheet GI-012, Agents.
Example 8
A non-resident asks an F.I.T. agent to put together a customized package according to the non-resident's choice of destination in Canada, mode of transportation, type of accommodation, and sites to visit. Each item is sold by different suppliers through the agent. The invoice shows one price for all of the items.
This package is not a tour package. Although the invoice only shows a single price, the items are sold separately through the agent.
Example 9
A tour operator puts together customized tours. They offer, as options, accommodation in Canada, meals, transportation, and tickets to various attractions and plays. Customers build their own packages by choosing one item from each option. The tour operator's invoice shows that the elements are combined together and sold for an all-inclusive price.
This package is a tour package. It includes a combination of property (accommodation, tickets to attractions or plays, meals) and a service (transportation). The property and service are combined together into a single supply and sold for an all-inclusive price.
Property, service, or amenity
29. To determine whether a tour package that includes short-term and/or camping accommodation in Canada also includes at least one service, it is necessary to determine what each element of the package would be, that is, property or a service, if it were supplied separately and not as part of a package. As part of this determination, it is important to distinguish between those elements that would be supplied separately and those elements that are inputs or part of another element, such as an amenity.
30. The term amenity is not defined in the ETA but is understood to mean an item that usually serves only to enhance an element and would generally not be supplied alone. Amenities are inputs or are part of another element. For example, housekeeping services at a hotel would not be an element supplied separately, but rather part of the accommodation. This is important when determining the nature of a supply, or in the case of a supply of a tour package, whether an item is an amenity or an element that could be supplied separately from the package.
31. To determine whether an item is an amenity, the Canada Revenue Agency usually considers the item's role in the tour package. If an item plays a minor or subordinate role, or if no part of the consideration can reasonably be attributed to it, it is likely an amenity. Some examples are:
- housekeeping at a hotel
- baggage handling
- parking in a parking lot
- access to a hotel facility
- complimentary transfers or shuttles to and from the accommodation and an airport, or shuttles to and from a nearby casino
32. Listed in paragraphs 33 and 34 of this memorandum are examples of elements that are either property or services. If a package that may be a tour package includes accommodations or a right to use a campground or trailer park in Canada and at least one service, and is supplied for an all-inclusive price, it is considered a tour package for GST/HST purposes. To simplify the examples listed, assume that the described packages are supplied for an all-inclusive price and that the accommodation or right to use a campground or trailer park is in Canada.
33. The following are examples of tour packages that include a combination of accommodation (property) and services:
- A package consists of accommodation, a guided sightseeing tour of the city, and meals. This package includes a service: the guided sightseeing tour.
- A package consists of accommodation, tickets to a show, and a guided tour of local wineries. This package includes a service: the guided tour of local wineries.
- A package consists of accommodation, transportation by minibus to and from a museum in a neighbouring city, and attendance at a festival. This package includes a service: the bus transportation.
- A package consists of accommodation, round-trip air transportation, guided sightseeing tours, and meals. This package includes two services. The air transportation and the guided sightseeing tours are both services.
- A package consists of accommodation, ski lift tickets, ski equipment rentals, and recreational ski lessons. This package includes a service: the ski lessons.
- A non-resident person plans to attend a convention in Canada. The sponsor of the convention has booked a block of rooms at a hotel at a convention rate. The non-resident person attending the convention decides not to reserve one of these rooms. Instead, the non-resident purchases a tour package from a tour operator. The tour package consists of round-trip air transportation and accommodation. The tour package includes a service: the air transportation.
34. The following are examples of packages that do not include at least one service, and therefore are not tour packages:
- A package consists of accommodation, meals, and theatre tickets. This package does not include a service. The meals and theatre tickets are both property.
- A package consists of accommodation and meals. In addition, the tour operator's representative is available in the hotel lobby each morning to sell optional guided tours to tourist attractions. This package does not include a service. The meals are property. The representative's presence in the hotel lobby is not a service. The representative is making separate supplies of optional guided tours and the representative's presence in the lobby merely facilitates the making of these supplies.
- A stay at an all-inclusive resort in Canada consists of accommodation at the resort, meals, access to a spa service at the resort spa, access to a supervised parking lot, and access to the hotel swimming pool and tennis court. This package does not include a service. In the case of an all-inclusive resort, items such as meals and access to the spa service at the resort spa, to the swimming pool, tennis court, and parking lot are amenities that are part of the accommodation.
- A package consists of accommodation, meals, and admission to a golf course. This package does not include a service. The meals and the admission to the golf course are both property.
- A package consists of accommodation in three different cities and a car rental. This package does not include a service. The car rental is property.
- A package consists of accommodation, ski lift tickets, and ski equipment rentals. This package does not include a service. The ski lift tickets and ski equipment rentals are both property.
- A package consists of accommodation, meals, and admission to a heritage site. This package does not include a service. The meals and the admission to a heritage site are both property.
- A package consists of accommodation at a hotel and a shuttle to and from a nearby casino. There is no charge for the shuttle. This package does not include a service. This is accommodation only as the shuttle is an amenity included in the accommodation.
Determining the consideration for the portions of a tour package
35. A tour package may include property and services taxable at different rates (that is, 0%, 5%, 13%, 14% or 15%) if supplied separately and not as part of the tour package. The tour package may also include property and services that, if supplied separately and not as part of the tour package, would be exempt or provided outside Canada, and therefore not subject to the GST/HST.
36. For information on when a supply is made in or outside Canada, refer to GST/HST Memorandum 3-3, Place of Supply.
37. The rules that apply in subsection 163(1) are used to determine the total amount of the GST/HST on a tour package by dividing the package into a taxable portion and a non-taxable portion. The taxable portion is then further subdivided into a non-provincially taxable portion and a provincially taxable portion (referred to as the relevant portion) and is explained in paragraphs 41 to 47 of this memorandum.
38. Under paragraph 163(1)(a), when a supply of a tour package is made by the first supplier (refer to paragraph 51 of this memorandum for the definition of this term), the consideration for the supply of the relevant portion is deemed to be the amount determined by the formula:
A × B
where:
39. Under paragraph 163(1)(b), when a supply of a tour package is made by a person other than the first supplier, the consideration for the supply of the relevant portion is deemed to be the amount determined by the formula:
A × B
where:
40. The result is that the person (the subsequent supplier) uses the same percentage for each portion that the first supplier used.
Taxable portion
41. Under subsection 163(3), the taxable portion of a tour package means "all property and services included in the tour package and in respect of which tax under Division II would be payable if the property or service were supplied otherwise than as part of a tour package".
42. Under subsection 163(3), the provincially taxable portion of a tour package, in respect of a participating province, means "all property and services that are included in the tour package and the supplies of which, if made otherwise than as part of the tour package, would be supplies made in the participating province in respect of which tax under subsection 165(2) would be payable".
43. Under subsection 163(3), the non-provincially taxable portion of a tour package means "all property and services included in the taxable portion of the tour package that are not included in the provincially taxable portions of the tour package".
44. In other words, the non-provincially taxable portion of a tour package refers to all property and services included in a tour package that, if supplied separately and not as part of the tour package, would be supplies made outside a participating province and subject to the GST. The taxable portion of a tour package is equal to the non-provincially taxable portion if none of the property and services included in the tour package would be supplies made in a participating province, if supplied separately and not as part of the tour package.
45. A supplier would only have to determine the provincially taxable portion of a tour package if the package included property or services which, if supplied otherwise than as part of the tour package, would be supplied in a participating province.
Non-taxable portion
46. The non-taxable portion of a tour package includes any property or services included in the tour package that, if supplied separately and not as part of the tour package, would be zero-rated or exempt, or otherwise not subject to tax. This would include certain international passenger transportation services, and accommodation provided outside Canada. Information on international passenger transportation services can be found in Appendix 2.
Example 10
A registrant sells a two‑week package that includes a 10‑day cruise from St. John's, Newfoundland and Labrador, to Iqaluit, Nunavut, two nights accommodation in St. John's, sightseeing in St. John's, two nights accommodation in Iqaluit, and sightseeing in Iqaluit. The registrant sells the package for an all-inclusive price.
The package includes property and services that, if supplied separately and not as part of the tour package, would be supplies made in Newfoundland and Labrador (a participating province). As a result, the registrant must determine the part of the taxable portion that is the provincially taxable portion and the part that is the non-provincially taxable portion, if any.
The following property and services, if supplied separately and not as part of the tour package, would be supplies made in Nunavut. They form the non-provincially taxable portion of the tour package:
- accommodation in Iqaluit
- sightseeing in Iqaluit
The following property and services, if supplied separately and not as part of the tour package, would be supplies made in Newfoundland and Labrador. They form the provincially taxable portion of the tour package:
- accommodation in St. John's
- sightseeing in St. John's
- 10-day cruise to Iqaluit (if supplied separately, this cruise would be supplied in Newfoundland and Labrador because the origin of the continuous journey, which includes this passenger transportation service, is in that province, and the termination and all stopovers are in Canada)
All property and services included in this tour package are in the taxable portion of the package. This tour package does not have a non-taxable portion.
47. For information on the place of supply of passenger transportation services, refer to GST/HST Memorandum 28-3, Passenger Transportation Services.
Separate supplies
48. Under subsections 163(2) and 163(2.1), for purposes of determining the GST/HST payable on a tour package, the provision of the non-provincially taxable portion, the provincially taxable portion, and the non-taxable portion are deemed to be supplies that are separate from, and not incidental to, the provision of the other portions, if any.
49. In addition, for purposes of determining the GST/HST payable on a tour package:
- The provision of the non-provincially taxable portion of the tour package is deemed to be a supply made outside a participating province, and therefore is taxable at the rate of 5%.
- The provision of the provincially taxable portion of the tour package is deemed to be a supply made in the participating province, and therefore is taxable at the HST rate for that particular province.
50. Under section 1 of Part VI of Schedule VI, the non-taxable portion of a tour package is a zero-rated supply.
Example 11
The registrant in Example 10 sells the two-week package.
For purposes of determining the GST/HST payable on the tour package, the registrant is deemed to have made separate supplies of the non-provincially taxable portion, which is taxable at a rate of 5%, and of the provincially taxable portion, which is taxable at a rate of 15%.
Taxable percentage of the relevant portion
First supplier
51. Under subsection 163(3), the first supplier in respect of a tour package means "the person who first supplies the package in Canada".
52. A person that purchases various property and services and then assembles these elements into a tour package, which the person then supplies in Canada, is the first supplier of the tour package. Similarly, a person that purchases an existing tour package and adds property and/or services to create a new tour package, which the person then supplies in Canada, is the first supplier of the new tour package.
53. A person that substitutes elements in an existing tour package that has already been sold may be the first supplier of a new tour package if the nature of the package has changed.
Example 12
A registrant purchases the two-week package described in Example 10 and adds it to its own one-week tour package. The registrant then supplies this new three-week tour package in Canada.
The registrant is the first supplier of the new three-week tour package.
Example 13
A registrant purchases the two-week package described in Example 10 and sells it to a consumer. For reasons beyond the registrant's control, the accommodation in St. John's is not available and the registrant has to substitute similar accommodation at a similar hotel in St. John's for the same price as the original accommodation.
The nature of the tour package has not changed, and therefore the registrant is not the first supplier of a new tour package.
54. The first supplier must calculate the taxable percentage for the non-provincially taxable portion of the tour package and/or the provincially taxable portion of the tour package, as the case may be.
Taxable percentage
55. Under subsection 163(3), the taxable percentage, "at a particular time, in respect of the provincially taxable portion of a tour package or the non-provincially taxable portion of a tour package, as the case may be, (in this definition referred to as the relevant portion) means:
- where the difference between the base percentage at that time in respect of the relevant portion and either the initial taxable percentage in respect of the relevant portion or the base percentage at an earlier time in respect of the relevant portion is more than 10 percentage points, the base percentage at the particular time in respect of the relevant portion, and
- in any other case, the initial taxable percentage in respect of the relevant portion".
56. Generally, the taxable percentage in respect of the relevant portion refers to the fraction that the first supplier uses to attribute the consideration for a tour package to that relevant portion of the tour package for purposes of determining the GST/HST payable on that portion of the package.
57. The taxable percentage is either the initial taxable percentage or the base percentage in respect of the relevant portion. In the majority of instances, the taxable percentage in respect of the relevant portion is equal to the initial taxable percentage in respect of the relevant portion, as calculated by the first supplier, when this supplier first determines the amount to be charged for the tour package. In situations where there is a significant change in the cost of acquiring the property and services included in the package, the taxable percentage in respect of the relevant portion is equal to the base percentage.
Initial taxable percentage
58. The first supplier of a tour package must establish which part of the tour package is the taxable portion and which part is the non-taxable portion.
59. Once the first supplier has determined the taxable portion of the tour package, the supplier calculates the initial taxable percentages for the relevant portion. Calculating the initial taxable percentage in respect of the relevant portion is required only once for any given tour package (that is, at the time the first supplier first determines the amount to be charged for the tour package).
60. Under subsection 163(3), the initial taxable percentage in respect of the relevant portion means the percentage determined, at the time the first supplier of the tour package first determines the amount (in this definition referred to as the initial price) to be charged by that supplier for a supply of the tour package, by the formula:
A ÷ B
where:
61. To calculate the initial taxable percentage in respect of the relevant portion, the first supplier divides the part of the initial cost of acquiring the property and services included in the tour package that is reasonably attributable to the relevant portion by the total initial cost of the property and services included in the package. Both amounts exclude any GST/HST paid on acquisition of the property and services (that is, input tax credits (ITCs)).
Example 14
The registrant in Example 10 incurs the following costs when acquiring the property and services included in the tour package (net of ITCs) at the time the registrant first determines the amount to be charged for the package:
Description of costs | Non-provincially taxable portion | Provincially taxable portion |
---|---|---|
Accommodation and sightseeing in Iqaluit | $450 | |
Accommodation and sightseeing in St. John's | $320 | |
10‑day cruise to Iqaluit | $1,500 | |
Total cost of each portion | $450 | $1,820 |
Total cost of tour package ($450 + $1,820) = $2,270
Relevant portions of tour package | Initial taxable percentage |
---|---|
Non-provincially taxable portion ($450 ÷ $2,270) | 20% |
Provincially taxable portion ($1,820 ÷ $2,270) | 80% |
62. As indicated in paragraph 57 of this memorandum, in most instances the taxable percentage in respect of the relevant portion is equal to the initial taxable percentage in respect of the relevant portion. Where there is a significant change in the costs of acquiring the property and services included in the tour package (as described below in paragraph 63), the first supplier may have to use the base percentage to determine the percentage of the consideration that is attributable to the relevant portion.
Base percentage
63. The cost of acquiring the property and services included in a tour package may change between the time that the first supplier first determined the amount to be charged for the package (when the first supplier determined the initial taxable percentage) and the time when the supply of the tour package is actually made. Generally, the proportion of the costs of acquiring the property and services included in the relevant portion as a percentage of the cost of all property and services included in the package at a later time is referred to as the base percentage.
64. Under subsection 163(3), the base percentage, at any time, in respect of the relevant portion means the percentage determined by the formula:
A ÷ B
where:
65. To calculate the base percentage for the relevant portion at a particular time, the first supplier divides the part of the cost of acquiring the property and services included in the tour package that is reasonably attributable to the relevant portion at that time by the total cost of all property and services included in the tour package at that particular time. Both amounts are net of ITCs.
Example 15
At the time the registrant in Example 14 supplies the tour package, the cost of acquiring the property and services included in the tour package has changed, as follows:
Description of costs | Non-provincially taxable portion | Provincially taxable portion |
---|---|---|
Accommodation and sightseeing in Iqaluit | $445 | |
Accommodation and sightseeing in St. John's | $265 | |
10‑day cruise to Iqaluit | $1,250 | |
Total cost of each portion | $445 | $1,515 |
Total revised cost of tour package ($445 + $1,515) = $1,960
Relevant portions of tour package | Initial taxable percentage | Base percentage | Difference |
---|---|---|---|
Non-provincially taxable portion | 20% | 23% ($445 ÷ $1,960) | 3% |
Provincially taxable portion | 80% | 77% ($1,515 ÷ $1,960) | 3% |
Since the difference between the base and initial taxable percentages in respect of the non-provincially taxable portion of the tour package is not more than 10 percentage points at the time the supply is made, the initial taxable percentage is used as the taxable percentage for purposes of determining the GST payable on the non-provincially taxable portion of the package.
Similarly, since the difference between the base and initial taxable percentages for the provincially taxable portion of the tour package is not more than 10 percentage points, the initial taxable percentage is used as the taxable percentage for purposes of determining the HST payable on the provincially taxable portion of the tour package.
Had the difference between the base and initial taxable percentages for a relevant portion been more than 10 percentage points, then the base percentage would have been used as the taxable percentage for purposes of determining the tax payable on that particular portion of the tour package.
66. In practice, the first supplier does not have to calculate the base percentage in respect of the relevant portion of a tour package if there has not been any change in the cost of acquiring the property and services included in the package since the time the supplier first determined the amount to be charged for the package (that is, where there is no change in the initial cost of acquiring the property and services included in the tour package).
67. A registrant that takes an existing tour package and adds property and/or services to it to assemble a new tour package becomes the first supplier of this new package. As the first supplier, the registrant must calculate the initial taxable percentage in respect of the relevant portions of the new tour package at the time it first determines the amount to be charged for the supply of the tour package. The registrant will then have to determine the base percentage in respect of the relevant portions of the new tour package at the time a supply is made (if there has been a change in its costs of acquiring the property and services included in the package) to determine which percentage to use as the taxable percentage for purposes of determining the tax payable on the relevant portion.
Example 16
Assume that the registrant in Example 14 is the first supplier of the tour package. The package is sold for $2,724. As discussed in Example 15, the cost of acquiring the property and services included in the tour package changed from the time the registrant first determined the amount to be charged for the package. The difference between the base and initial taxable percentages for each of the relevant portions is not more than 10 percentage points, and therefore the taxable percentage for each relevant portion is equal to the initial taxable percentage for each relevant portion. The consideration and tax for the respective relevant portions is calculated as follows:
Taxable portion | Taxable percentage | Consideration for the supply of the tour package | Consideration for the relevant portions |
---|---|---|---|
Non-provincially taxable portion | 20% | $2,724.00 | $544.80 |
Provincially taxable portion | 80% | $2,724.00 | $2,179.20 |
The registrant charges the following amounts with respect to the supply of the tour package.
Details | Amount |
---|---|
Consideration for the supply of the tour package | $2,724.00 |
GST ($544.80 × 5%) | $27.24 |
HST ($2,179.20 × 15%) | $326.88 |
Total ($2,724.00 + $27.24 + $326.88) | $3,078.12 |
Example 17
A subsequent supplier that is registered for the GST/HST purchases the tour package described in Example 15 for resale to a consumer. The registrant in Example 15 charges, and the subsequent supplier pays, $2,724 plus tax for the tour package. The subsequent supplier will claim ITCs where eligible.
The registrant in Example 15 informs the subsequent supplier that it used the following taxable percentages in respect of the supply of the tour package:
- 20% for the non-provincially taxable portion
- 80% for the provincially taxable portion
The subsequent supplier sells the tour package to a consumer for $3,269.00 and uses the same percentages to determine the consideration for the relevant portions as follows:
- consideration for the non-provincially taxable portion ($3,269.00 × 20%) = $653.80
- consideration for the provincially taxable portion ($3,269.00 × 80%) = $2,615.20
The subsequent supplier charges the following amounts with respect to the supply of the tour package to the consumer:
Details | Amount |
---|---|
Consideration for the supply of the tour package | $3,269.00 |
GST ($653.80 × 5%) | $32.69 |
HST ($2,615.20 × 15%) | $392.28 |
Total ($3,269.00 + $32.69 + $392.28) | $3,693.97 |
Documentation
68. The first supplier of a tour package must maintain documentation to show how the taxable percentage of the package was calculated.
Insurance
69. Under section 1 of Part VII of Schedule V, most supplies of financial services are exempt. Subsection 123(1) defines a financial service to include the issuance of a financial instrument, such as an insurance policy. The supply of an insurance policy by an insurer (generally a person that is licensed under the laws of Canada or a province to carry on an insurance business) to a traveller is generally an exempt supply of a financial service.
70. A tour operator is generally not an insurer that is licensed under the laws of Canada or a province to carry on an insurance business and, accordingly, does not generally supply an insurance policy to a traveller. However, a tour operator may arrange for an insurer's supply of an insurance policy to the traveller. If so, the insurance premium payable by the traveller (which is collected by the tour operator on behalf of the insurer) would not be included in the tour package as the insurance is not part of what is being supplied by the tour operator.

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Decision tree – Text version
- Is it a supply of a tour package?
- If the answer is No, use the general rules to determine if the supply is taxable and calculate the amount of tax to charge.
- If the answer is Yes, go to question 2.
- Are you the first supplier of the tour package?
- If the answer is No, go to question 3.
- If the answer is Yes, go to question 6.
- Did you add/subtract elements to/from the package (such as, add a sightseeing excursion)?
- If the answer is Yes, you may be the first supplier of a new package. If so, begin by characterizing this supply.
- If the answer is No, go to question 4.
- Did you substitute elements in the package (such as, substitute one hotel for another)?
- If the answer is No, use the first supplier's taxable percentage for the relevant portion to calculate the amount of tax to charge.
- If the answer is Yes, go to question 5.
- Did substituting the elements change the nature of the package?
- If the answer is No, use the first supplier's taxable percentage for the relevant portion to calculate the amount of tax to charge.
- If the answer is Yes, you may be the first supplier of a new package. If so, begin by characterizing this supply.
- When you first determine the price to be charged for the tour package, what is the initial taxable percentage for the provincially taxable portion and the non-provincially taxable portion, as the case may be (that is, the relevant portion)?
When you sell the tour package, is the difference between the base percentage for the relevant portion at that time and either the initial taxable percentage for the relevant portion or the base percentage for the relevant portion at an earlier time, greater than 10 percentage points?- If the answer is No, the taxable percentage for the relevant portion equals the initial taxable percentage for the relevant portion.
- If the answer is Yes, the taxable percentage for the relevant portion equals the base percentage for the relevant portion at that time.
- Is it a supply of a tour package?
Appendix 2 – Certificate of zero-rated entitlement
The taxable portion of a tour package means all property and services included in the package on which the GST/HST would be payable if the property or service were supplied otherwise than as part of a tour package (other than zero-rated supplies of property and services). Generally, the supply of a domestic passenger transportation service is included in the taxable portion of a tour package.
There may be situations where the supply of a domestic passenger transportation service is included in the non-taxable portion of a tour package. This may be the case where a tour operator purchases a domestic passenger transportation service from a registered supplier, and then provides the service to an individual as part of a single supply of a tour package. If the domestic transportation service were supplied separately and not as part of a tour package, the service might be a zero-rated leg of a continuous journey supplied to that individual. Generally, the journey must be an international continuous journey. More information on determining whether a passenger transportation service is a leg of an international continuous journey can be found in GST/HST Memorandum 28-3.
A tour operator may purchase a domestic passenger transportation service that is a leg of an international continuous journey from a registered supplier, on a zero-rated basis, where the tour operator provides the supplier with sufficient documentation, such as a certificate of zero-rated entitlement, a tour itinerary, and a passenger list. With respect to this documentation, the following applies:
- The tour itinerary must describe all elements of the passenger transportation services (including those provided by the registered supplier) that form the international continuous journey, including the origin, destination, stopovers, arrival and departure dates, and all modes of conveyance.
- The passenger list must contain the names and addresses of the travellers, however, if the supplier agrees, the tour operator can keep the passenger list and provide it on request.
The following is an example of a certificate of zero-rated entitlement that a tour operator may use when purchasing a domestic passenger transportation service that is a leg of an international continuous journey from a supplier.

Certificate of zero-rated entitlement - image description
The zero-rated entitlement certificate contains the following fields:
- To: {Enter the name and address of registered supplier of transportation service}
- We hereby certify that the following transportation services that we have purchased from you, namely: {Enter a detailed description of the required services the registered supplier will provide} will be included in one or more tour packages and will qualify for zero-rated status under the Excise Tax Act. We will pay the GST/HST in respect of any transportation service found to be taxable at 5%, 13%, 14% or 15% during an audit of {Enter the name of the registered supplier}
- Dated at {enter location} this {enter the day} day of {enter the month}, {enter the year} {enter the name and address of tour operator}
- {Enter the signature of the tour operator or authorized representative}
- {Enter name of the authorized representative – please print}
- {Enter the title of the authorized representative}
If presented with a certificate of zero-rated entitlement, a supplier should determine if the conditions for zero-rating its transportation services are met. If the conditions are not met then the supplier must charge the GST/HST.
The supplier must maintain sufficient documentary evidence that the tour operator resold the services on a zero-rated basis. The supplier will have to decide whether the information provided by the tour operator is sufficient as the supplier may be assessed if sufficient documentation has not been maintained.
Further information
All GST/HST technical publications are available at GST/HST technical information.
To make a GST/HST enquiry by telephone:
- for GST/HST general enquiries, call Business Enquiries at 1‑800‑959‑5525
- for GST/HST technical enquiries, call GST/HST Rulings at 1‑800‑959‑8287
If you are located in Quebec, call Revenu Québec at 1‑800‑567‑4692 or visit their website at revenuquebec.ca.
If you are a selected listed financial institution (whether or not you are located in Quebec) and require information on the GST/HST or the QST, go to GST/HST and QST information for financial institutions, including selected listed financial institutions or:
- for general GST/HST or QST enquiries, call Business Enquiries at 1‑800‑959‑5525
- for technical GST/HST or QST enquiries, call GST/HST Rulings SLFI at 1‑855‑666‑5166
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