GST/HST Memorandum 3-3-6-1, Place of Supply in a Province – Personal Services, Services in Relation to Property and Telecommunication Services, April 2026

Principles for determining if a service is in relation to TPP

35. It must first be determined whether the service is designed, developed, or...

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Principles for determining if a service is in relation to TPP/ allocation of real estate

49. Before applying the specific place of supply rules,...

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Service in relation to realty held in disparate locations sited under the s. 18 rule

Example 36

• A Newfoundland and Labrador company hires a New...

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• CRA states, presumably based on Club Intrawest, that where a supply of a service relates to real property that is situated both in Canada and...

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Meaning of advisory or consulting service

19. An advisory service is not defined in the ETA but generally means a service of giving an opinion, or...

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Vehicle was in a participating province only 40% of the time when the testing service was performed there

Example 20

An Ontario company is hired...

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Distinguishing character of supply of telecommunication service

62. A supply is generally considered to be a supply of a telecommunication...

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