In a March 28, 2023 Technical Interpretation (245256, Marlene Legare), CRA opined that the additional fee that merchants can charge as of October 2022 for accepting payment via credit card (see VTN 502(1)) would be a separate supply of a financial service and therefore exempt if the following conditions are met:

  • it is charged to the cardholder solely for the acceptance of the use of the credit card as a payment method and is not charged if another payment method is used;
  • it is imposed by (and is thus the revenue of) the merchant who provides to the cardholder the property or service that is purchased with the use of the credit card and not by a person who acts as a billing agent or payment service provider in facilitating the payment;

whether the fee is shown and charged separately

  • it is subject to the relevant credit card network rules relating to surcharging, including rules regarding the calculation and level of the surcharge; and
  • it is shown and charged separately to the cardholder.
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