Osteopathic Service Providers

GST/HST Info Sheet GI-198
May 2022

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 HST applies in the participating provinces at the following rates: 13% in Ontario and 15% in New Brunswick, Newfoundland and Labrador, Nova Scotia and Prince Edward Island. The GST applies in the rest of Canada at the rate of 5%. If you are uncertain as to whether a supply is made in a participating province, refer to GST/HST Technical Information Bulletin B-103, Harmonized Sales Tax – Place of Supply Rules for Determining Whether a Supply is Made in a Province.

Meaning of significant terms

For the purpose of this publication:

Manual osteopathic service provider means a provider of osteopathic services who is not an osteopathic physician.

Osteopathic physician means a licensed osteopathic physician, a doctor of osteopathic medicine, a doctor of osteopathy (D.O.) or an osteopath who is entitled under the laws of a province to practise medicine.

GST/HST exemptions for supplies of osteopathic services

Osteopathic physicians

In certain provinces (including Alberta, British Columbia, Ontario and Quebec) the practice of osteopathy by osteopathic physicians is regulated in conjunction with the practice of medicine. In these provinces, osteopathic physicians are admitted to the College of Physicians and Surgeons of the province and are entitled to practise the profession of medicine in that same province.

Supplies of osteopathic services rendered by osteopathic physicians are exempt from the GST/HST under section 5 of Part II of Schedule V. This section exempts supplies of health care services rendered to an individual by a medical practitioner (a person who is entitled under the laws of a province to practise the profession of medicine or dentistry) provided that the service is a qualifying health care supply and is not a cosmetic service supply.

For more information on qualifying health care supplies, refer to GST/HST Policy Statement P-256, Qualifying Health Care Supplies and the Application of the GST/HST to Supplies of Medical Examinations, Assessments, Reports and Certificates.

Licensed practitioner

Where osteopathic services are not rendered by an osteopathic physician, the services may be exempt from the GST/HST under section 7 of Part II of Schedule V. For the exemption to apply, the following conditions must all be met:

• the service is rendered to an individual by a practitioner as defined in section 1 of Part II of Schedule V
• the service is an osteopathic service
• the service is a qualifying health care supply according to section 1.2 of Part II of Schedule V
• the service is not a cosmetic service supply or a supply, in respect of a cosmetic service supply, that is not made for medical or reconstructive purposes according to section 1.1 of Part II of Schedule V

Practitioner

To be a practitioner in respect of osteopathic services, section 1 of Part II of Schedule V requires that a person must:

• practise the profession of osteopathy
• where the person is required to be licensed or otherwise certified to practise the profession of osteopathy in the province in which the service is supplied, have the licence or certification
• where the person is not required to be licensed or otherwise certified to practise the profession of osteopathy in that province, have the qualifications equivalent to those necessary to be so licensed or otherwise certified in another province

When a person is licensed or otherwise certified to practise a particular health profession in a province, they are governed by the regulatory body responsible for the regulation of the health profession in that province. The role of these regulatory bodies and the authority to monitor and regulate their respective health professions is set out in provincial legislation.

Manual osteopathic service providers

Manual osteopathic service providers who provide osteopathic services, hereafter referred to as “manual osteopathic services”, are not currently members of a regulated health profession in any province or territory in Canada. Presently there are no provincial or territorial licensing requirements for manual osteopathic service providers. Therefore, they cannot meet the requirement to be licensed or certified or have the equivalent qualifications to be licensed or certified in another province or territory. As such, they are not practitioners for GST/HST purposes.

In some provinces, manual osteopathic service providers may be members of associations that promote the practice of their members. Membership in these associations is not required in order to provide manual osteopathic services in that province. Non-members may also provide manual osteopathic services in the provinces where such associations are present. The association may set its own professional standards but this is not the same as regulating manual osteopathic service providers under provincial legislation. Therefore, membership in such an association does not meet the requirements set in the definition of practitioner.

In order for the exemption in section 7 of Part II of Schedule V to apply to a supply of a service, all four conditions for exemption listed above must be met. Since a manual osteopathic service provider is not a practitioner for GST/HST purposes, the first condition is not met. It is therefore not necessary to determine whether the remaining conditions for exemption in section 7 of Part II of Schedule V are met.

As a manual osteopathic service provider is not a practitioner for GST/HST purposes, supplies of osteopathic services rendered by a manual osteopathic service provider do not meet the conditions for exemption in section 7 of Part II of Schedule V. If the manual osteopathic service provider is a GST/HST registrant, they must collect and remit the GST/HST on their supplies of manual osteopathic services at the applicable rate depending on the province in which the service is supplied.

Provision of a variety of services

Some health professionals may offer a variety of services, some of which might require professional licensing. For example, a manual osteopathic service provider may supply manual osteopathic services alongside other health care services, such as physiotherapy services or massage therapy services. The other health care services can be exempt where the supply meets the conditions for an exempting provision. For example, supplies of physiotherapy services are exempt where the service is rendered to an individual by a practitioner of the service within the scope of the profession of physiotherapy.

Where a person provides services that are taxable and services that are exempt, it is important that the person identifies which supplies are subject to the GST/HST and that the person collects and remits the GST/HST for those supplies if they are a registrant. For example, if a member of the regulated profession of physiotherapy renders supplies of physiotherapy services and of manual osteopathic services to their patient, only the supplies of physiotherapy services are exempt. The physiotherapist must collect and remit the GST/HST in respect of the manual osteopathic services they supply if they are a registrant.

It is necessary to determine the correct tax treatment as it can affect when a person becomes a registrant and the amount of input tax credits (ITCs) that a person can claim. These are explained in further detail below.

Requirement to register for the GST/HST

Where a manual osteopathic service provider makes taxable supplies in Canada in the course of a commercial activity in which they are engaged, they are required to be registered for the GST/HST, unless they are a small supplier, as detailed below.  

Generally, suppliers who, along with any associates (if they were associated at the beginning of the particular calendar quarter), exceed $30,000 in total revenue (before expenses) from most taxable supplies of property and services in a single calendar quarter or over the previous four consecutive calendar quarters must register for the GST/HST.

Suppliers who, along with any associates (if they were associated at the beginning of the particular calendar quarter), do not exceed $30,000 in total revenue (before expenses) from taxable supplies of property and services in a single calendar quarter or over the previous four consecutive calendar quarters may still choose to register voluntarily for a GST/HST account.

For more information on the $30,000 small supplier threshold, refer to GST/HST Memorandum 2-2, Small suppliers, and go to When to register for and start charging the GST/HST.

Mixed supplies of health care services

It may be challenging for a manual osteopathic service provider to determine when they have passed the small supplier threshold in respect of their taxable services and are required to register for GST/HST purposes. In particular, this may be the case in circumstances where a manual osteopathic service provider is also a supplier of exempt health care services, such as chiropractic services or occupational therapy services.

Where this is the case, the supplier must calculate what revenue (before expenses) is attributable to taxable supplies and what revenue is attributable to exempt supplies in order to determine whether they are a small supplier. 

Educational approach

In September 2020, the Canada Revenue Agency (CRA) published in Excise and GST/HST News – No 108 an article entitled “The application of GST/HST to manual osteopathic services”. This article outlines the tax status of supplies of manual osteopathic services rendered by manual osteopathic service providers who are not medical practitioners (licensed physicians or dentists) for GST/HST purposes.

The CRA understands that some in the osteopathic community may have believed that their services were exempt and had not registered for the GST/HST. To assist the community, the CRA has taken an educational approach and has encouraged manual osteopathic service providers to register if they are not a small supplier. All manual osteopathic service providers who are not a small supplier must collect, file and remit the GST/HST on their manual osteopathic services. Suppliers must register for the GST/HST in order to claim ITCs on eligible purchases. ITCs are explained in further detail below.

When a manual osteopathic service provider became aware of the requirement to register for the GST/HST, they were required to do so.

The CRA reserves the right to assess retroactively where continuous and/or severe non-compliance is observed for the period prior to the publication of the article. This could be the case where a manual osteopathic service provider was previously advised by the CRA that their supplies of services were taxable and that they were required to register, and they neglected to do so.

For more information, go to When to register for and start charging the GST/HST.

Input tax credits

A GST/HST registrant is generally eligible to claim ITCs to recover the GST/HST paid or payable on taxable property and services to the extent that the property or services are acquired, imported or brought into a participating province by the registrant for consumption, use or supply in the course of its commercial activities, that is, for the purpose of making taxable supplies for consideration (and not for the purpose of making exempt supplies).

ITCs may also be available for GST/HST that became payable before the person becomes a registrant, to the extent that the tax relates to property or services consumed, used or supplied in the course of the person’s commercial activities after the person becomes a registrant.

For more information on determining whether a person can claim an ITC, refer to GST/HST Memorandum 8-1, General Eligibility Rules.

For more information on calculating ITCs, refer to GST/HST Memorandum 8-3, Calculating Input Tax Credits, and go to Input tax credits.

Further information