CRA considers conference attendance fees to be for IPP rather than services supplies for HST purposes

CRA has indicated that where members of a national organization are charged separate fees for a conference to be held at a Canadian location, that fee will be characterized for purposes of the HST place-of-supply rules as being consideration for a supply of intangible personal property, so that the location of the conference will govern the place of supply.

If CRA had instead considered that the fee was for a service, a potential complication would have arisen: if the individual attended the conference, the place-of-personal-performance rule (in s. 17) might govern; whereas if the individual was to be a "no show" (which might not be known, if at all, until after the fee was charged), the recipient's business address rule (in s. 13(1)) might govern.

Neal Armstrong.  Summaries of 17 January 2013 Ruling Case No. 130479 under New Harmonized Value-Added Tax System Regulations, ss. 6(1) and 8.