2024 GSTHST Memoranda Outlining Place of Supply Rules

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.