Before finding that fleet insurance policies issued by the appellant to trucking companies who operated their vehicles in both Canada and the U.S were in part zero-rated under ETA Sched VI, Pt. IX, s. 2(d), which covers insurance under a policy “that relates to risks that are ordinarily situated outside Canada,” Webb JA stated (at para. 26):
Section 2 of Part IX of Schedule VI only applies to financial institutions that issue insurance policies. It does not apply to a person who acquires an insurance policy. Since this section is limited to financial institutions that issue insurance policies, in my view, the word “risks” should be interpreted from the perspective of the insurance companies.