2024 GSTHST Memoranda Outlining Place of Supply Rules

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Figure 1. Magic Studio AI Art, 2024. “Canada Place of Supply Rules”

The frequently referenced GST/HST Technical Information Bulletin B-103 "Harmonized Sales Tax – Place of supply rules for determining whether a supply is made in a province", released in early 2010, has been partially replaced in August 2024 by the Canada Revenue Agency (CRA). Three of the eight new GST/HST memoranda, that are replacing the GST/HST Technical Information Bulletin B-103, were released. For GST/HST registrants and specialists, the thirty one (31) chapters of the GST/HST Memoranda Series are an informative resource that offers context and explanation of a variety of GST/HST regulations from the CRA's point of view.   

Rather than addressing the GST/HST place of rules in a single document, the new GST/HST memos handle the place of supply rules by broad categories. The following are the new memoranda in this series that have been published by the CRA, as of October 14, 2024:

1.      GST/HST Memorandum 3-3-2, Place of Supply in a Province – Overview

2.      GST/HST Memorandum 3-3-3, Place of Supply in a Province – Tangible Personal Property

3.      GST/HST Memorandum 3-3-4, Place of Supply in a Province – Real Property

The remaining GST/HST memoranda, including one specifically explaining the regulations for transportation services, and one specifically for intangible personal property, are currently being developed by the CRA. Until the remaining memoranda are released, GST/HST registrants and specialists can still consult the GST/HST Technical Information Bulletin B-103 for guidance on the GST/HST place of supply regulations for intangibles and services, including transportation services.