Words and Phrases - "advisory service"

A resident registrant (CanCo) provided, to non-resident clients from a location in Canada, digital advertising, digital marketing, content marketing strategy and social media services.

CRA ruled that such services were not zero-rated under ETA Sched. VI, Pt. V, s. 8 as supplies of an advertising service made to an unregistered non-resident person, given that those services did not themselves entail creating advertising messages, and did not directly relate to communicating such messages. However, it noted that such services might be zero-rated under Sched. VI, Pt. V, s. 7 or s. 23. Regarding s. 7, it stated:

The CRA generally interprets an advisory service to mean a service of giving an opinion, or counsel, or of recommending a plan or course of action, while a consulting service refers to a service of providing information, instruction or expert advice; a consultant generally provides services relating to a field of specialized knowledge or training. An advisory or consulting service may address business, management, marketing, data processing, public relations, or other issues or problems faced by the client. However, such service is not considered to include any work that might be undertaken or performed as a result of the plans or recommendations accepted by the client or the advice provided to the client.