Excise Tax Act — E-15 179
lar property made by a non-resident person that is not registered under Subdivision D of Division V, (ii) for the purpose of making a taxable supply in Canada of a service of manufacturing or producing other tangible personal property to a non-resident person that is not registered under Subdivision D of Division V and is not a consumer of the other property, if the particular property (A) is incorporated or transformed into, attached to, or combined or assembled with, the other property in the manufacture or production of the other property, or (B) is directly consumed or expended in the manufacture or production of the other property, (iii) if the particular property is not property of a person that is resident in Canada, for the purpose of making a taxable supply in Canada of a commercial service in respect of the particular property to a non-resident person that is not registered under Subdivision D of Division V and is not a consumer of the particular property, or (iv) for the purpose of making a taxable supply in Canada of a commercial service in respect of other tangible personal property (other than property of a person that is resident in Canada) to a non-resident person that is not registered under Subdivision D of Division V and is not a consumer of the other property, if the particular property (A) is incorporated into, attached to, or combined or assembled with, the other property in the provision of the commercial service, or (B) is directly consumed or expended in the provision of the commercial service, and (d) the consignee gives to the registrant, and the registrant retains, a certificate that (i) states the consignee’s name and registration number assigned under section 241, (ii) acknowledges that the consignee is acquiring physical possession of the particular property as the recipient of a supply referred to in subparagraph (c)(i) or for a purpose referred to in any of subparagraphs (c)(ii) to (iv), and (iii) acknowledges that the consignee is assuming liability to pay or remit any amount that is or may become payable or remittable by the consignee (A) under Division IV in respect of the particular property, or (B) under this Part in respect of a supply, deemed under paragraph (1)(d) to have been made by the consignee, of the particular property or of the other property referred to in either of subparagraphs (c)(ii) or (iv), the following rules apply: (e) paragraphs (1)(d) to (g) do not apply to the taxable supply referred to in subparagraph (a)(i) or the acquisition referred to in subparagraph (a)(ii), as the case may be, and (f) if subparagraph (a)(i) applies, the taxable supply referred to in that subparagraph is deemed to have been made outside Canada. Exception — certificate of registered owner (3) For the purposes of this Part, if (a) paragraphs (1)(a) to (c) apply to (i) a taxable supply in respect of particular tangible personal property that is made by a registrant and is referred to in any of subparagraphs (1)(a)(i) to (iii), or (ii) an acquisition by a registrant of physical possession of particular tangible personal property that is referred to in subparagraph (1)(a)(iv), (b) the transfer referred to in paragraph (1)(b) of physical possession of the particular property is to a person (in this subsection referred to as the “consignee”) that is not entitled, under subsection (2), to give to the registrant a certificate described in paragraph (2)(d) in respect of that transfer, (c) either (i) the particular property is, immediately after the particular time referred to in paragraph (1)(b), property of a particular person that is registered under Subdivision D of Division V and that is neither the registrant nor the consignee, and the registrant retains a certificate that (A) is given to the registrant by the particular person, (B) states the particular person’s name and registration number assigned under section 241, (C) acknowledges that the particular property is, immediately after the particula