The GST/HST and QST systems rely heavily on transaction documentation. The Tax Court of Canada (TCC) confirmed this principle in Dow & Duggan Log Homes International (1993) Limited v. The Queen, 2019 TCC 280 (CanLII). As a reminder, the supply of tangible personal property (TPP) may not be subject to GST/HST and QST when, in the case of a sale, it is delivered to the recipient outside Canada or is, or will be, made available outside Canada, or in the case of a supply by way of lease, it is made available to the recipient outside Canada (see 142(2)(a) and
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