Do Dietitians Charge GST/HST in Canada? The Test Is Not Clinical vs Wellness

Are dietitian services exempt from GST/HST?

Generally yes, when the three statutory conditions are met. Section 7.1 of Part II of Schedule V to the Excise Tax Act exempts a supply of a dietetic service made by a practitioner of the service. Dietetics is not among the professions listed in section 7 — it has its own standalone section, and citing section 7 for a dietitian is a common error in secondary sources.

Revenu Québec's own examples show where the line actually falls. The health services it names as taxable — kinesiology, massage therapy, homeopathy, fasciatherapy — are taxable because those providers are not practitioners for GST/QST purposes, not because the work is preventive. It says so outright for manual osteopathy: taxable because the people who practise it are not considered practitioners. Dietitians are on the practitioner list. So the widely repeated rule that preventive or wellness-oriented work is automatically taxable does not come from the Act. What is genuinely unsettled is narrower and more useful to know: the Act does not define "dietetic service", and no published CRA ruling addresses a dietitian selling wellness coaching, a digital product, or one-to-one counselling billed to an employer.

Section 7.1 has three alternative recipient limbs, not one. The supply qualifies if the service is rendered to an individual, or the supply is made to a public sector body, or it is made to the operator of a health care facility. "Public sector body" is broad — under section 123(1) it takes in non-profit organizations, charities, municipalities, school authorities, hospital authorities and universities.

Meeting section 7.1 is necessary but not sufficient. Section 1.2 overrides the rest of the Part — everything except sections 9 and 11 to 14: a supply that is not a qualifying health care supply is deemed not to be included in Part II at all, and is therefore generally taxable.

Is preventive or wellness nutrition counselling taxable?

Not on the strength of being preventive. The definition of qualifying health care supply in section 1 lists five purposes: maintaining health, preventing disease, treating or relieving an injury or illness, assisting an individual in coping with one, and providing palliative health care. Prevention and health maintenance are the first two.

CRA states this directly in Policy Statement P-256 (May 2022): services made for the purposes of maintaining health and preventing disease do not require the individual to have an injury, illness, disorder or disability. The widely repeated framing — that a service must connect to an existing illness to be exempt — does not come from the Act or from CRA policy.

A second tax authority publishes the same test in its own words. Revenu Québec, setting out when GST and QST must be charged on a health service, lists as one trigger that the service is not rendered for one of five purposes — and names them as maintaining health, preventing disease, treating or relieving an injury, illness, disorder or disability, assisting an individual in coping with one, and providing palliative care. Drafted as the negative, it puts maintaining health and preventing disease inside the exemption just as the federal Act does.

Where a supply has more than one purpose, the test is the dominant or main purpose, assessed at the time the supply is made. A purpose that arises later is irrelevant. And the practitioner carries the burden: CRA states the supplier is responsible for determining whether a supply qualifies and for maintaining sufficient documentation to demonstrate it. For a solo practice that is an operational obligation, not an abstraction.

Which province's registration matters if I see clients virtually?

The client's. Whether you are a "practitioner" for GST/HST turns on being licensed or otherwise certified to practise in the province in which the service is supplied — not the province where you live or where your practice is based. The place-of-supply rules generally locate the supply at the recipient's address obtained in the ordinary course of business.

That makes cross-province virtual practice a tax question and a licensure in the client’s province question at the same time, and the two point in the same direction. A dietitian registered elsewhere in Canada must hold Ontario registration to provide dietetic services to clients located in Ontario, including virtually. The tax analysis and the college analysis both follow the client.

When does a dietitian have to register for GST/HST?

When taxable supplies exceed $30,000 — and exempt revenue does not count toward that figure. "Taxable supply" means one made in the course of a commercial activity, and commercial activity excludes the making of exempt supplies. A practice whose work is exempt can therefore bill well past $30,000 without approaching the threshold.

The threshold counts your taxable supplies plus those of your associates, made inside or outside Canada, over the four preceding calendar quarters. There is also a faster trigger: exceeding $30,000 within a single calendar quarter ends small-supplier status immediately before the supply that crossed it, so tax applies to that supply rather than from the next quarter.

The corollary is the part that surprises people. A practitioner making only exempt supplies generally cannot register at all — voluntary registration requires being engaged in a commercial activity. And because input tax credits are keyed to use in commercial activities, GST/HST paid on the practice's own inputs is not recoverable. "Exempt" is not unambiguously good news.

How does QST work for a Quebec dietitian practice?

The rest of the Quebec picture — retention, insurance, and the prohibition on taking payment in advance — is in the Quebec practice in full.

As a separate statute, not as a pointer to the federal one. The Act respecting the Québec sales tax mirrors the federal exemption almost word for word in section 114.1, and its qualifying health care supply definition and section 1.2 analogue are structured the same way — but the QST practitioner test requires licensure in Quebec specifically.

The QST rate is 9.975%, imposed by its own charging section, and QST registration is a separate statutory obligation with its own small-supplier rule on the same $30,000 figure and the same single-quarter mechanics. Revenu Québec names "diététiste" in its published list of practitioners whose services are not subject to GST or QST.

Rates elsewhere are less uniform than they look. GST is 5%; in a participating province the HST is that 5% plus a prescribed provincial component. The instrument that prescribes it differs by province — Ontario's provincial component is not in the current prescribed-rates regulation, so the Act falls back to Schedule VIII for Ontario, while Schedule VIII is out of date for Nova Scotia, New Brunswick and Newfoundland and Labrador and silent on Prince Edward Island. Check the rate for the specific province rather than a single national source.

What has CRA not answered?

The cases practitioners most often ask about. The Excise Tax Act does not define "dietetic service", and no published CRA ruling, interpretation or bulletin addresses a registered dietitian supplying wellness coaching, a digital product such as a recorded course or meal-plan PDF, or one-to-one counselling of employees under a contract paid by an employer.

Section 7.1's first limb asks whether the service is rendered to an individual, and CRA has published what that phrase means — in its bulletins for acupuncture and naturopathy, the service must involve a professional relationship with the individual for the purpose of meeting that individual's health care needs. In both bulletins a practitioner hired by an employer to deliver a group workshop to staff is taxable on the fee charged to the employer. Neither bulletin is about dietitians and neither addresses one-to-one counselling an employer happens to pay for, so the dietitian-specific case is genuinely open — but anyone assuming a corporate workshop is exempt is assuming against CRA's published reading of the same words.

Bundling is the one case that is answered, and answered more favourably than most guidance assumes. Section 7.4 of Part II of Schedule V exempts a single supply where all or substantially all of the consideration is reasonably attributable to two or more services that would each be exempt under sections 5 to 7.3 if supplied separately, and dietetic services fall in that range. CRA's Notice 311 lists "dietetic service practitioners" among the professionals whose services can be combined this way, and a 2024 interpretation works the threshold at 90%. It bites hard: where more than a tenth of a package's consideration is attributable to a non-exempt provider, the whole package is taxable rather than the offending slice being carved out. So a weight-management package built from a dietitian and a psychotherapist can be exempt, while the same package built from a dietitian and a kinesiologist can be fully taxable.

An older interpretation is still cited for the bundling method, and it should not be cited for its outcome: in 1995 CRA analysed a multidisciplinary weight-loss program as a single supply and found it taxable — but that turned on the supplier not being a health care facility, under a version of the law predating both section 1.2 and section 7.4, and it quotes GST at 7%.

Private-insurer reimbursement is also unresolved. Section 9 exempts a supply to the extent its consideration is payable by a provincial health plan; it does not speak to private carriers. P-256 addresses assessments an insurer requests, which is a different thing from an ordinary client-paid session later reimbursed. If your practice sits in one of these gaps, that is a question for your accountant, and the honest answer is that the published guidance does not reach it.

One drafting note for anyone checking this themselves: the list of exempt practitioner services is amended over time — paragraph 7(f) was repealed in 2026 — so confirm currency against the consolidated Act rather than a summary.