In the Interpretation Letter 17-038655-001, Revenu Québec summarizes the steps that must be taken to determine the application of the health care exemptions under Part II of Schedule V of the Excise Tax Act (ETA) and the corresponding measures in the Act Respecting the Québec Sales Tax.

“Part II of Schedule V to the ETA (Part II) provides for supplies of health care services that are exempt for the purposes of the ETA, excluding the following supplies that are deemed not to be included in Part II, namely

• • Except for the purposes of section 9 of Part II, cosmetic services and related supplies that are not made for medical or reconstructive purposes;
  • Except for the purposes of sections 9 and 11 to 14 of Part II, supplies that are not qualifying health care supplies.

The terms qualifying health care supply and cosmetic service supply are defined in section 1 of Part II as follows:

“Qualifying health care supply means a supply of property or a service that is made for the purpose of

1. 1. maintaining health,
   2. preventing disease,
   3. treating, relieving or remediating an injury, illness, disorder or disability,
   4. assisting (other than financially) an individual in coping with an injury, illness, disorder or disability, or
   5. providing palliative health care.

Cosmetic service supply means a supply of property or a service that is made for cosmetic purposes and not for medical or reconstructive purpose”

It should be noted that under section 9 of Part II, any supply of property or services for which consideration is payable or reimbursed by a provincial health insurance plan (e.g., Quebec’s health insurance plan) is exempt. Such a supply does not fall within the exclusions for cosmetic service supplies and qualifying health care supplies.

To determine whether a health service is exempt, it is first necessary to consider whether it is covered by any of the provisions of Part II. If so, it must then be determined whether the conditions of the exempting provision are met and whether the above restrictions set out in sections 1.1 and 1.2 of Part II are applicable. In general, a health service rendered by a person other than a health professional included in one of the exemptions provided for in Part II is taxable.” Our unofficial translation

In this interpretation letter, RQ concludes that the services performed by a fasciatherapist using the Danis Bois method are not covered by the exemption provided for in Part II.