A martial arts centre runs an after-school programme and a summer camp. It also runs skills workshops and hosts birthday parties. To the operator these are four versions of the same business. To the Excise Tax Act they are not.
Key Takeaway
Section 1 of Part IV of Schedule V exempts a supply of child care services the primary purpose of which is to provide care and supervision to children 14 years of age or under for periods normally less than 24 hours per day. CRA states the term child care services is not defined in the Act. In one 2019 ruling CRA held that the same corporation's professional development day camps were exempt while its workshops, birthday party packages and prepaid passes were all taxable. Because the supply is exempt rather than zero-rated, the operator recovers no input tax credits, so on our own figures the unrecoverable tax can approach six percent of revenue.
A Note On Currency
Everything here is stated as verified in August 2026 and requires confirmation before reliance.
Our principal source is GST/HST Memorandum 21-1, Child Care Services, dated December 2019[1]. CRA states in it that the information does not replace the law found in the Act and its regulations[1].
We rely on three CRA rulings given to other taxpayers[2][3][4]. Two carry CRA's notice that although correct at the time of issue they may not represent the current position of the Agency[2][4]. None binds CRA in respect of anyone else.
Rulings are published in severed form, with identifying details removed. Several passages we quote contain bracketed redactions, and we have not filled them in.
One source is a consumer tax software publication which we identify because we disagree with part of it[6], and one is an operator's own guidance page[7].
This is not tax advice. Whether a particular programme is exempt turns on its own facts, and this is an area where CRA plainly expects operators to ask.
The Exemption
The provision, which is one sentence and does all the work.
CRA states that a supply of child care services, the primary purpose of which is to provide care and supervision to children 14 years of age or under for periods normally less than 24 hours per day is generally exempt under section 1 of Part IV of Schedule V[1].
Four elements, and each can fail independently. This breakdown is ours.
Primary purpose must be care and supervision. Not education, not recreation, not instruction.
Care and supervision is the specific pairing. Both words appear.
Children 14 years of age or under. A hard age line.
Periods normally less than 24 hours per day. The word normally softens it, but the 24 hour reference brings overnight arrangements into question.
CRA illustrates the ordinary case with an example: an individual arrives at 6:45 in the evening to babysit toddlers until midnight while their parents are away from the home, and is making an exempt supply[1].
A second example begins with an individual offering child care services for three children aged two to four for up to eight hours per weekday[1]. We did not obtain the remainder of that example and do not state its conclusion.
The Term Is Not Defined
The gap at the centre of the provision.
CRA states plainly that the term child care services is not defined in the Act[1].
An operator's own guidance page makes the same observation from the other side, noting that CRA does not provide a clear definition of child care services and works instead from the primary purpose formulation[7].
Three consequences, ours.
The analysis is entirely functional. There is no list of qualifying programme types to check against.
The test therefore falls back on what the programme is actually for, judged on its facts, which is why so much of the guidance in this area is rulings rather than rules.
And it means naming a programme does not classify it. Calling something a camp does not make it child care, and calling something a class does not make it education.
CRA's memorandum directs readers who need certainty to request a ruling, citing Memorandum 1-4 on how to obtain one[1]. In an area with an undefined central term and a body of published rulings, that is not boilerplate. It is the intended route.
Primary Purpose, Not Activity
The test that decides everything. This section is our own analysis.
Operators naturally classify by what happens in the room. Children doing martial arts, children painting, children outdoors.
The provision classifies by why the supply exists. A parent who needs their child looked after between three and six is buying care and supervision, whatever the children do during it.
Three implications.
The same activity supports both answers. Art in an after-school programme is enrichment within a care service. Art in a Saturday morning class that a parent attends alongside the child is something else.
The customer's need is evidence of purpose. Programmes timed to the school day and the working day look like care. Programmes timed to leisure hours look like recreation or instruction.
And the marketing describes the purpose. A business that advertises measurable skill outcomes is telling a reader, and an auditor, what it is selling.
We would put the practical test this way: if the programme were cancelled, would the parent need to arrange alternative supervision, or would the child simply miss a class? The first points at care. The second does not.
Enrichment Does Not Defeat It
A ruling that gives operators real comfort.
In a 2017 ruling concerning summer day camps and after-school programmes at a martial arts centre, CRA held the supplies exempt, stating that although the children's programmes are enriched by recreational and athletic activities, the primary purpose of the programmes is to provide care and supervision to children 14 years of age and under[2].
Commentary summarising the ruling records the same conclusion, that the exemption applied to the supply by a registrant of summer day camp and after-school programs at its martial arts centre for children under 14[5].
Two observations, ours.
The word enriched is doing important work. CRA treats the athletic content as an addition to a care service rather than as the service itself.
Which means a programme does not have to be unstructured to qualify. An operator running a full timetable of activities is not thereby outside the exemption.
That is worth stating because the opposite belief is common. Operators sometimes assume that a professionally programmed day, with instructors and a curriculum of activities, must be education or recreation rather than care. On this ruling, it need not be.
The other side of that comfort is the ruling described next, from a business that also ran camps.
One Business, Three Answers
The ruling this article is named for, and the clearest illustration available.
A 2019 ruling addressed a corporation's supplies of children's workshops, camps, professional development day camps, events and a prepaid item severed from the published text[4].
CRA reached different conclusions across that single product line.
The professional development day camps were held exempt from GST/HST under section 1 of Part IV of Schedule V, so GST/HST should not be charged on those supplies[4].
The workshops were held taxable. CRA reasoned that they were not tutoring or instruction in a course approved for credit by, or that follows a curriculum designated by, a school authority, so were not exempt under that provision, and that there are no other exempting provisions available in the ETA for this type of supply[4].
The birthday party packages were held taxable, so GST/HST should be charged on them[4].
And the prepaid item was held taxable, for reasons set out in the next section[4].
Two observations, ours.
The phrase there are no other exempting provisions available is the important one. CRA did not merely find the workshops outside the tutoring exemption; it recorded that nothing else in the Act rescued them.
And the practical consequence for that operator is a business selling four things to the same families from the same premises, obliged to charge tax on three and not on the fourth, with the classification depending on what each product is for.
The Pass Is Taxable Even When The Camp Is Not
A subtle point from the same ruling, and one that catches operators who sell prepaid credit.
CRA's reasoning on the prepaid item was that it entitles the purchaser to register for workshops or camps, that there are no restrictions in the use of it, such as when it can be used or the type of workshop or camp that can be attended, and that consequently the supply is for the right to attend a future workshop or camp supplied by the corporation, which is taxable for GST/HST purposes[4].
Our own reading of what drove that.
The absence of restrictions appears to be decisive. Because the item could be used for anything the corporation offered, it could not be characterised as a payment for a particular exempt supply.
So what was sold was a right to attend something unspecified, which is its own supply and takes its own treatment.
Two practical consequences.
An operator selling open-ended passes, credits or gift certificates should not assume they inherit the treatment of the programmes they will eventually be spent on.
And the reasoning suggests a restricted instrument might be analysed differently, since the absence of restrictions is what CRA relied on. We say might, because we did not obtain any ruling addressing a restricted pass and we are not going to assert a result CRA has not given.
Tutoring Is Narrower Than People Say
The educational exemption, which is far tighter than its reputation.
CRA states that paragraph 9(a) of Part III of Schedule V exempts a supply of a service of tutoring or instructing an individual in a course that is approved for credit by, or that follows a curriculum designated by, a school authority, and that school authority means an organization that operates an elementary or secondary school in which it provides instruction meeting provincial standards[3].
Read the conditions, and this is our own analysis.
The exemption attaches to the course, not to the tutor and not to the subject. It must be approved for credit, or follow a designated curriculum.
The approving body is a school authority, being an organisation operating an elementary or secondary school to provincial standards.
So the question is not whether the tutoring is educational. It is whether the specific course carries that approval or follows that curriculum.
Three consequences.
Tutoring a student in their actual school subject, on the provincial curriculum, is the case the exemption was written for.
General enrichment, test preparation, coding clubs, language classes and study skills are not obviously within it, and an operator should establish rather than assume.
And CRA applied exactly this reasoning to hold workshops taxable in the ruling above[4], which shows the provision being used as a boundary rather than a general educational exemption.
A Loose Summary Worth Correcting
A widely available consumer description that we think misleads.
A consumer tax software publication lists among exempt supplies: educational services, including vocational school courses, tutoring, and music lessons, and describes the child care exemption as covering babysitters and daycare providers who take care of children under the age of 14 for less than 24 hours a day[6].
Two problems, ours.
Listing tutoring without qualification omits the conditions that decide it. On CRA's statement of paragraph 9(a), tutoring is exempt where the course is approved for credit or follows a designated curriculum, and CRA has held workshops taxable precisely because they were not[3][4].
And under the age of 14 is not the statutory line. The provision says 14 years of age or under[1], which includes fourteen-year-olds. A summary excluding them narrows the exemption by a full year.
We are not suggesting bad faith. Consumer summaries compress, and compression in this area removes the conditions that carry the answer.
The point for an operator is narrower and worth stating: a general list of exempt supplies is not usable as a classification tool for a business whose products sit near a boundary. The conditions are the subject, not a footnote to it.
Exempt Is Not Relief For The Operator
The consequence operators least expect, and the reason this classification cuts both ways. This section is our own analysis.
An operator hearing that their supplies are exempt reasonably treats it as good news. No tax to charge, no tax to remit, nothing to explain to parents.
The cost sits on the other side of the ledger.
A supply that is exempt carries no entitlement to input tax credits. The operator pays GST or HST on its rent, its utilities, its equipment, its food, its professional fees and its repairs, and recovers none of it.
That is the difference between exempt and zero-rated, which this publication has addressed separately. A zero-rated supplier charges nothing and recovers everything. An exempt supplier charges nothing and recovers nothing.
Three consequences.
The tax becomes an operating cost buried in every invoice, invisible because it never appears as a separate line the business tracks.
It is not passed to parents as tax. It is passed to them as price, or absorbed as margin.
And it means the exemption is a consumer-facing relief, not an operator-facing one. Parents pay no tax on fees. The operator pays tax on everything it buys.
What The Lost Credits Cost
The magnitude, computed by us on an illustrative operator with $600,000 of revenue.
Assume taxable inputs of $132,000 of rent and utilities, $54,000 of food and consumables, $38,000 of programme supplies and equipment, $26,000 of professional and administrative services and $18,000 of repairs and maintenance.
That is $268,000 of taxable inputs. At 13 percent, the tax is roughly $34,840, and none of it is recoverable.
As a share of revenue, that is roughly 5.81 percent.
Two observations, ours.
Just under six percent of revenue is a substantial figure in a sector that operates on thin margins and where fees are constrained by what families can pay and, in some provinces, by regulation.
And it is structurally invisible. There is no line in the accounts called unrecoverable tax; it is distributed across every expense account in the ledger.
We stress that the input figures are our own assumptions for illustration and that an actual operator's proportions will differ. The purpose is to show that the number is material rather than trivial, which is the thing most operators have never calculated.
Why Premises-Heavy Operators Suffer Most
A refinement that determines who is hit hardest. This section is our own analysis.
The largest single cost in child care is staff, and wages carry no GST or HST. There is nothing to recover and nothing lost.
So the burden of exempt status falls in proportion to the non-wage share of the cost base.
Three consequences.
An operator in expensive leased premises carries a large unrecoverable amount, because commercial rent is typically taxable.
An operator that invests in equipment, fit-out or a building incurs tax on capital spending that it cannot recover, which changes the economics of expansion.
And an operator whose costs are overwhelmingly wages, such as a home-based provider, loses comparatively little.
That produces an outcome worth naming: the exemption is least costly to the smallest operators and most costly to those investing in facilities. Whether that was intended we do not know, and we are not going to speculate about policy. But an operator modelling a new site should put the unrecoverable tax on the capital budget, because it is a real cost that a taxable business would not bear.
The Mixed Operator Must Apportion
The position of the business in the 2019 ruling, and of most operators of any size.
An operator making both exempt and taxable supplies can recover tax on inputs to the taxable side and not on inputs to the exempt side, and inputs used for both must be apportioned.
Our own illustration, using the same $34,840 of input tax and a simple revenue-share apportionment.
At 80 percent exempt, roughly $6,968 recoverable and $27,872 stranded.
At 50 percent, roughly $17,420 each way.
At 20 percent exempt, roughly $27,872 recoverable and $6,968 stranded.
Three cautions, and they matter.
A revenue-share apportionment is our simplification. We did not research the method required, which may depend on use rather than revenue, and an operator must establish the correct basis.
Registration is a separate question. An operator making only exempt supplies may not be required or able to register, while a mixed operator has taxable supplies that count toward the small supplier threshold.
And the apportionment has to be documented and consistent, because it is a calculation an auditor can reperform.
The Fifteenth Birthday
A boundary that moves during a season. This section is our own analysis.
The exemption covers children 14 years of age or under[1]. A child who turns fifteen is outside it.
Our own illustration on a programme charging $2,400 a place.
With 90 children all 14 or under, taxable revenue is nil.
With 72 under and 18 over, taxable revenue is $43,200 and the tax to collect at 13 percent is roughly $5,616.
With 60 under and 30 over, taxable revenue is $72,000 and roughly $9,360 of tax.
Three practical points.
An operator running programmes for a mixed age range, which describes most camps, has mixed supplies by default rather than by choice.
The classification depends on a fact in the registration record, which means date of birth is a tax field as well as a safety one.
And a child can cross the line mid-programme, which raises a timing question we did not research and which an operator with teenagers in its programmes should raise specifically.
Overnight Changes Things
The fourth element of the test.
The exemption applies to care and supervision for periods normally less than 24 hours per day[1].
CRA's info sheet on children's camps operated by public sector bodies sets out a table in which a camp for children 14 years of age and under that does not include overnight supervision is exempt; a camp for children over 14 that does not include overnight supervision is taxable; a camp for children over 14 that includes overnight supervision is taxable; and camps for children who are underprivileged or who have a disability are exempt[8].
Two observations, ours.
The table pairs age with overnight status, which confirms both matter and that they interact.
And the fragment we obtained does not show the row for children 14 and under with overnight supervision. We are not going to infer it. The main exemption's reference to periods normally less than 24 hours per day plainly raises a question about residential camps, and an operator running one needs the answer from the source rather than from our reading of a partial table.
The separate exemption for camps serving underprivileged children or children with a disability is worth noting as a distinct category that does not depend on the age line in the same way.
A Table That May Not Be Yours
A caution about the source of that table.
The info sheet is titled Children's Camps Operated by Public Sector Bodies[8].
That matters, and this is our own point.
Public sector bodies, which include municipalities, charities and certain non-profits, are subject to their own exempting provisions in addition to the general ones, and this publication has addressed the non-profit and charity regimes separately.
So a table published for that population may reflect provisions unavailable to a commercial operator, and a private camp business should not adopt it as a summary of its own position.
We use it here for what it shows about the interaction of age and overnight supervision, which is consistent with the general provision, and we flag that its scope is narrower than its content appears.
An operator that is itself a charity or non-profit is in a different analysis again, and should start from the provisions applicable to that status rather than from the child care exemption alone.
The Unaccompanied Minor Exclusion
A specific carve-out from the exemption.
CRA states that the exemption does not apply to a supply of a service of supervising an unaccompanied child made by a person in connection with a taxable supply by that person of a passenger transportation service[2].
Two observations, ours.
The obvious application is an airline or bus operator charging a fee to supervise a child travelling alone. That is supervision of a child under 14, and without the carve-out it might have qualified.
The carve-out prevents a component of a taxable transport supply from being separated out and treated as exempt care.
The general principle behind it is worth extracting, and it is ours: supervision provided as an adjunct to a different taxable supply does not become exempt child care merely because the person supervised is a child.
That reasoning may bear on other arrangements where supervision accompanies a taxable service, and an operator in that position should consider the point rather than assume the carve-out is confined to transport.
The Incentive Runs Backwards
An observation about how operators respond, which is ours.
In most of the classification disputes in this series, the taxpayer wants the relieving treatment. A staffing agency wants its supplies exempt; a bakery wants its goods zero-rated.
Here the incentive is genuinely ambiguous.
Exempt means no tax on fees, which parents notice, and no input tax credits, which the operator absorbs.
Taxable means tax on fees, which parents notice more, and full recovery on inputs.
For a premises-heavy operator serving fee-sensitive families, neither is obviously better, and the answer is not the operator's to choose in any event.
Two practical consequences.
An operator should compute both positions before assuming which it would prefer, because the input tax credit side is frequently larger than expected.
And where a business genuinely has a mix, the proportions matter commercially rather than only for compliance, since they determine how much of the input tax is recoverable.
None of that licenses arranging products to reach a preferred answer. The classification follows primary purpose, and CRA has shown in the rulings above that it will look product by product.
What The Auditor Actually Examines
The enquiry in practice. This section is our own analysis.
The product list, and whether every item has been classified rather than the business treated as uniformly exempt.
Programme descriptions and marketing, which state the purpose in the operator's own words.
Registration records including dates of birth, against the age line.
Ancillary offerings, being parties, workshops, merchandise, meals sold separately and events.
Prepaid passes, credits and gift certificates, and whether their use is restricted.
The input tax credit claim, and whether any credits were claimed against exempt activity.
The apportionment method where the operator is mixed, and whether it is documented and consistently applied.
The sixth item deserves emphasis. An operator that treats itself as exempt but claims credits on some inputs has an internal inconsistency that is visible from its own return, and it invites the classification question rather than answering it.
What Records Survive
A written classification of every product, with the reasoning and the provision relied on.
Programme descriptions as published, retained by period, since marketing evidences purpose.
Registration records with dates of birth and programme dates.
Terms of any pass, credit or gift certificate, showing what restrictions apply.
The apportionment calculation for input tax credits, with its basis.
Any ruling obtained, filed with the programme description it was given on.
Evidence of provincial curriculum approval where a tutoring exemption is claimed.
What To Do
Classify product by product, not business by business. CRA held one corporation's camps exempt and its workshops, parties and passes taxable in a single letter.
Ask what the parent is buying. The test is primary purpose, and care and supervision is a different purpose from instruction or recreation.
Do not assume enrichment defeats the exemption. CRA held a martial arts centre's camps exempt despite recreational and athletic content.
Treat passes and gift certificates separately. An unrestricted right to attend future programmes was held taxable even though some of those programmes were exempt.
Check the tutoring conditions before relying on that exemption. It requires a course approved for credit or following a curriculum designated by a school authority.
Use 14 or under, not under 14. Fourteen-year-olds are inside the exemption, and at least one widely read summary gets this wrong.
Compute the unrecoverable input tax. On our figures it can approach six percent of revenue, and most operators have never quantified it.
Put it on the capital budget. Tax on fit-out and equipment is unrecoverable against exempt activity, which changes the cost of expansion.
Document the apportionment if you are mixed. It is a calculation an auditor can reperform.
Get a ruling for anything near a boundary. The central term is undefined, CRA says so, and the published rulings show operators routinely asking.
The Limits Of This Analysis
Several caveats matter. This is not tax advice; classification turns on the facts of each programme. Everything is stated as verified in August 2026 and requires confirmation. Our principal source is a CRA memorandum dated December 2019 which states that its information does not replace the law. We rely on three rulings given to other taxpayers, none of which binds CRA in respect of anyone else, and two of which carry CRA's notice that they may not represent the Agency's current position. Those rulings are published in severed form and several passages we quote contain redactions we have not filled in. We did not obtain the conclusion of CRA's second worked example in the memorandum and do not state it. The camps table we cite is published for public sector bodies and may reflect provisions unavailable to a commercial operator, and the fragment we obtained does not include the row for children 14 and under with overnight supervision, which we expressly decline to infer. We did not research the input tax credit apportionment method required and our revenue-share illustration is a simplification. We did not research registration and small supplier mechanics for mixed operators, the timing question where a child crosses the age line mid-programme, provincial regulation or subsidy interaction, or the separate regimes applying to charities and non-profits, which this publication addresses elsewhere. All arithmetic is our own, uses assumed input proportions, an assumed rate and hypothetical enrolment, and is illustrative only. The primary purpose framing, the premises-heavy analysis, the observation that the incentive is ambiguous and the audit examination structure are our own.
Frequently Asked Questions
Is our day camp exempt?
Can some of our programmes be exempt and others taxable?
Being exempt is good news, isn't it?
What about the gift passes we sell?
Is tutoring exempt?
Does a fourteen-year-old count?
References
- Canada Revenue Agency. GST/HST Memorandum 21-1, Child Care Services, December 2019, on the memorandum explaining the GST/HST exemption for supplies of child care services under section 1 of Part IV of Schedule V; on the information in the publication not replacing the law found in the Act and its regulations; on a supply of child care services, the primary purpose of which is to provide care and supervision to children 14 years of age or under for periods normally less than 24 hours per day, being generally exempt; on the term child care services not being defined in the Act; on readers requiring certainty being able to request a ruling, with Memorandum 1-4 explaining how; on an example of an individual babysitting toddlers from 6:45 pm until midnight being an exempt supply; and on a further example beginning with an individual offering child care services for three children aged two to four for up to eight hours per weekday. Note: a CRA primary publication; we did not obtain the conclusion of the second example and do not state it. canada.ca
- Canada Revenue Agency GST/HST Ruling 183644, 16 November 2017, as reproduced by a tax publication service, concerning summer day camps and afterschool programs, on a supply of child care services whose primary purpose is to provide care and supervision to children 14 years of age or under for periods normally less than 24 hours per day being exempt; on that exemption not applying to a supply of a service of supervising an unaccompanied child made by a person in connection with a taxable supply by that person of a passenger transportation service; and on CRA's finding that although the children's programmes were enriched by recreational and athletic activities, the primary purpose of the programmes was to provide care and supervision to children 14 years of age and under. Note: a ruling given to another taxpayer, accessed through a secondary reproduction and published in severed form; it carries CRA's notice that although correct at the time of issue it may not represent the Agency's current position. taxinterpretations.com
- Canada Revenue Agency GST/HST Ruling 207167r, 15 September 2023, as reproduced by a tax publication service, concerning acting programs, on section 1 of Part IV of Schedule V exempting a supply of child care services the primary purpose of which is to provide care and supervision to children 14 years of age or under for periods normally less than 24 hours per day; on child care services potentially including services provided at a day camp; on paragraph 9(a) of Part III of Schedule V exempting a supply of a service of tutoring or instructing an individual in a course that is approved for credit by, or that follows a curriculum designated by, a school authority; on school authority meaning an organization that operates an elementary or secondary school in which it provides instruction meeting provincial standards; and on most supplies of property and services made in Canada being taxable unless specifically identified as exempt, with exempt supplies listed in Schedule V. Note: a ruling given to another taxpayer, accessed through a secondary reproduction and published in severed form. taxinterpretations.com
- Canada Revenue Agency GST/HST Ruling 179132, 25 February 2019, as reproduced by a tax publication service, concerning children's workshops, camps, professional development day camps and events, on the corporation's workshops not being tutoring or instruction in a course approved for credit by, or following a curriculum designated by, a school authority, so not exempt under that provision, and on there being no other exempting provisions available in the ETA for that type of supply so that a workshop is taxable; on a prepaid item entitling the purchaser to register for workshops or camps with no restrictions on when it can be used or the type of workshop or camp that can be attended, so that the supply is for the right to attend a future workshop or camp and is taxable; on the professional development day camps being exempt under section 1 of Part IV of Schedule V so that GST/HST should not be charged; and on the birthday party packages being taxable so that GST/HST should be charged. Note: a ruling given to another taxpayer, accessed through a secondary reproduction and published in severed form; it carries CRA's notice that although correct at the time of issue it may not represent the Agency's current position. taxinterpretations.com
- Tax Interpretations. CRA Finds That a Summer Day Camp and After-School Program Qualified as Child Care Services for GST/HST Purposes, summarising ruling 183644, on the exemption applying to the supply by a registrant of summer day camp and after-school programs at its martial arts centre for children under 14, and on CRA's statement that although the children's programmes were enriched by recreational and athletic activities the primary purpose was to provide care and supervision to children 14 years of age and under. Note: a commentary summary of the ruling at reference 2. taxinterpretations.com
- Intuit TurboTax Canada. A Guide to GST/HST Exemptions: What Goods and Services Are Exempted?, listing among exempt supplies health, medical and dental services provided by licensed physicians and dentists for medical reasons; childcare services described as babysitters and daycare providers who take care of children under the age of 14 for less than 24 hours a day; educational services described as including vocational school courses, tutoring and music lessons; financial services; and legal aid services. Note: a consumer tax software publication. We cite it because we disagree with two aspects of its summary, as discussed in the text: it describes the age line as under 14 where the provision says 14 or under, and it lists tutoring without the conditions that determine whether the exemption applies. turbotax.intuit.ca
- Tideview Nature School. Do I Need to Charge GST/HST for My Canadian Forest School?, on CRA not providing a clear definition of child care services and instead treating services whose primary purpose is to provide care and supervision to children 14 years of age or under for periods normally less than 24 hours per day as exempt, citing GST/HST Memorandum 21-1; and on such programmes typically falling under the exemption while a programme whose primary focus is education or recreation may not qualify. Note: an operator's own guidance page rather than professional advice; we use it for its description of the definitional gap. tideviewnatureschool.ca
- Canada Revenue Agency. GST/HST Info Sheet GI-037, Children's Camps Operated by Public Sector Bodies, setting out that a camp for children 14 years of age and under that does not include overnight supervision is exempt; that a camp for children over 14 years of age that does not include overnight supervision is taxable; that a camp for children over 14 years of age that includes overnight supervision is taxable; and that camps for children who are underprivileged or who have a disability are exempt; and stating that the information in the publication does not replace the law found in the Excise Tax Act and its regulations. Note: a CRA publication addressed to public sector bodies, which may reflect provisions unavailable to commercial operators. The fragment we obtained does not include a row for children 14 and under with overnight supervision, and we decline to infer it. canada.ca
This article is provided for general informational purposes and is not tax advice. Three CRA rulings given to other taxpayers are relied on; none binds CRA in respect of anyone else, two carry CRA's notice that they may not represent its current position, and all are published in severed form with redactions we have not filled in. A CRA table cited here is published for public sector bodies and may not apply to commercial operators. All arithmetic is the authors' own and is illustrative only.