Excise Tax Act — E-15 217
e the certificate referred to in that section is not in effect at the time the supply is made, or (ii) the recipient does not export the property in the circumstances described in paragraphs 1(b) to (d) of that Part; or (e) a supply of property that is a zero-rated supply only because it is included in section 1.2 of Part V of Schedule VI, if the recipient is not acquiring the property for consumption, use or supply exclusively in the course of commercial activities of the recipient and (i) an authorization of the recipient to use the certificate referred to in that section is not in effect at the time the supply is made, or (ii) the recipient is not acquiring the property for use or supply as domestic inventory or as added property (as those expressions are defined in subsection 273.1(1)). ( fourniture taxable importée ) loading means any part of the value of the consideration for a supply of a financial service that is attributable to administrative expenses, an error or profit margin, business handling costs, commissions, communications expenses, claims handling costs, employee compensation or benefits, execution or clearing costs, management fees, marketing or advertising costs, occupancy or equipment expenses, operating expenses, acquisition costs, premium collection costs, processing costs or any other costs or expenses of a person that makes the supply, other than commissions for a specified financial service or the part of the value of the consideration that is equal to (a) if the financial service includes the issuance, renewal, variation or transfer of ownership of an insurance policy but not of any other qualifying instrument, the total of (i) the estimate of the net premium of the insurance policy, and (ii) if the insurance policy is a policy of reinsurance, the margin for risk transfer of the insurance policy; (b) if the financial service includes the issuance, renewal, variation or transfer of ownership of a qualifying instrument (other than an insurance policy), the estimate of the default risk premium that is directly associated with the qualifying instrument; and (c) if the financial service includes the issuance, renewal, variation or transfer of ownership of an insurance policy and a qualifying instrument (other than an insurance policy), the amount determined by the formula A + B where A is the total of (i) the estimate of the net premium of the insurance policy, and (ii) if the insurance policy is a policy of reinsurance, the margin for risk transfer of the insurance policy, and B is the estimate of the default risk premium that is directly associated with the qualifying instrument. ( chargement ) margin for risk transfer means an amount payable to a particular insurer by another insurer under an agreement for the supply of a financial service, which includes the issuance, renewal, variation or transfer of ownership of a policy of reinsurance issued by the particular insurer, that exclusively represents compensation for the assumption, by the particular insurer, of the risk of potential future claims under particular insurance policies issued by the other insurer and that is in addition to the estimate of the net premium of the policy of reinsurance. ( marge de transfert de risques ) permitted deduction for a specified year of a qualifying taxpayer means an amount that is (a) consideration for a supply of property or a service, or the value of imported goods, upon which tax under this Part (other than section 218.01 or subsection 218.1(1.2)) became payable during the specified year by the qualifying taxpayer; (b) tax referred to in paragraph (a) in respect of a supply or importation referred to in that paragraph; (c) a provincial levy that is prescribed for the purposes of section 154 and is in respect of a supply referred to in paragraph (a); (d) an amount that is deemed, under subsection 248(18) or (18.1) of the Income Tax Act , to be assistance repaid by the qualifying taxpayer in respect of property or