New Harmonized Value-added Tax System Regulations, No. 2 — 27
(E/F) × (365 - G) where E is the total of all consideration (other than consideration referred to in section 167.1 of the Act that is attributable to goodwill of a business) for taxable supplies (other than supplies of financial services and supplies by way of sale of real property that is capital property of the particular person) made in Canada, or made outside Canada through a permanent establishment in Canada, by the particular person that became due to the particular person during the 12-month period immediately preceding the recapture period or that was paid to the particular person in that 12-month period without having become due, in relation to the business acquired by the particular person, F is the number of days in the 12-month period immediately preceding the recapture period that are after that time, and G is the number of days in the 12-month period immediately preceding the recapture period that are after that time and that are in the base year. Consideration (4) For the purposes of subsection (3), consideration for a supply of property or a service includes (a) any amount that would, in the absence of subsection 153(4) of the Act, be included in the consideration for the supply; (b) any amount that would, in the absence of subsection 156(2) of the Act, be consideration for the supply; and (c) if the supply is made between persons not dealing at arm’s length, any amount by which the consideration is less than the fair market value of the property or service at the time the supply is made. Large business — partnership (5) If a member (other than an individual) of a partnership acquires property or a service, or brings it into a specified province, for consumption, use or supply in respect of the activities of the partnership but not on the account of the partnership and the partnership is a large business, for the purposes of the definition large business in subsection 236.01(1) of the Act, the member is a prescribed person at any time in respect of that acquisition or bringing in if, at that time, the member is a registrant. Large business — joint venture (6) If an operator (within the meaning of subsection 273(1) of the Act) that is a participant in a joint venture with a large business under an agreement referred to in that subsection acquires property or a service, or brings it into a specified province, under the agreement on behalf of the large business in the course of the activities for which the agreement was entered into and, at the time of the acquisition or bringing in, an election under subsection 273(1) of the Act made by the operator and the large business is in effect, for the purposes of the definition large business in subsection 236.01(1) of the Act, the operator is a prescribed person at any time in respect of that acquisition or bringing in. Large business — acquisition of control (7) If, at any time in a recapture period, a person that is a large business acquires control of a corporation that is not a large business, the corporation and any persons associated with the corporation are, for the period beginning at that time and ending on the last day of the recapture period that includes the last day of the fiscal year of the corporation that includes that time, prescribed persons for the purposes of the definition large business in subsection 236.01(1) of the Act. Large business — amalgamation (8) If, at any time in a recapture period, two or more corporations (each of which is referred to in this subsection as a “predecessor”) are merged or amalgamated to form one corporation (in this subsection referred to as the “new corporation”) and the sum of the recapture input tax credit threshold amounts of the predecessors in respect of the recapture period exceeds $10,000,000, the new corporation is, for the period beginning at that time and ending on the last day of the recapture period that includes the last day of the first fiscal year of the new corporation, a prescribed person for the purpos