Rule of origin
61. Generally, where the origin is specified on the ticket or voucher issued in respect of the first passenger transportation service in a continuous journey (or the origin is otherwise known to be in a province), and the termination and all stopovers in respect of the continuous journey are in Canada, the province in which the origin is located will determine whether the supply is made in a participating province or a non-participating province.
Stopover outside Canada trumps Ontario origin
64. Where there is a termination or a stopover outside Canada in respect of a continuous journey, the passenger transportation services in that continuous journey are deemed to have been made in a non-participating province and are subject to the GST, regardless of the origin.
An individual purchases a return air ticket from Ottawa, Ontario to Boston, Massachusetts, USA. Ottawa is specified as the origin of the continuous journey on the ticket.
Although the ticket issued in respect of the first passenger transportation service in the continuous journey specifies that the origin of the continuous journey is in Ontario, there is a stopover outside Canada in respect of the continuous journey. The supply of the passenger transportation service is therefore made in a non-participating province and subject to the GST at the rate of 5%.