CRA indicates that the office location of the hiring office generally will determine the province in which services are supplied for HST purposes

CRA has stated that where a supplier of services obtains more than one address of its client in the ordinary course of its business, it will be the location of the office of the client which hired the supplier which will determine the province where the service is supplied for HST purposes (assuming rules for the situs of special types of services, such as real estate services, do not apply).  In a recently released example, CRA indicated that this rule would apply even where the services supplier (a personnel placement company) entered into a specific contract for each individual that it placed with the client that named only the specific work location for that individual (which might be in a different province from that of the HR people who had hired the personnel company).

Neal Armstrong.  Summary of 31 October 2011 Headquarters Letter 132350 under New Harmonized Value-Added Tax System Regulations. s. 13(1).