Members of a national organization (who provide their business address) pay annual fees for membership and separate fees for admissions to conferences held at various locations in Canada. After referencing the ss. 6(1) and 7 rules, CRA stated:
Based on the facts, the Registration fees that the [Organization] collects from individuals who attend a particular […] conference are consideration for a supply of IPP in respect of which the Canadian rights can only be used in the province in which the […] conference takes place. Therefore, if the conference takes place in a participating province, the supply of the IPP is made in that participating province. If the conference takes place in a non-participating province, the supply of the IPP is made in a non-participating province.
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