In the course of finding that the single-supply doctrine should not be applied to treat the supply of an orthodontic appliance and a related supply of orthodontic services to a patient as a single supply of exempt healthcare services (the orthodontic services), Woods JA stated (at para. 42):
It is highly unlikely that Parliament would explicitly provide that any supply of an orthodontic appliance is zero-rated if the intention is that the supply is restricted to the wholesale level. Such imprecise drafting is not typical of taxing statutes in general or in the ETA.