Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.
Principal Issues: Whether an online marketplace for event tickets is a "platform" as defined under subsection 282(1) of the Act, specifically, whether it connects sellers to other users "for the provision of relevant services or the sale of goods" as required by the definition.
Position: Likely no, but it is a question of fact.
Reasons: The marketplace appears to facilitate the transfer of an intangible right to attend an event (whether evidenced electronically or by paper), and does not otherwise facilitate the provision of relevant services, specifically, personal services.
XXXXXXXXXX 2025-108196
Kate Li
February 5, 2026
Re: Online marketplace for the sale of event tickets and the definition of “platform” in subsection 282(1)
Unless stated otherwise, all statutory references in this document are to the Income Tax Act (Canada), R.S.C. 1985, c.1 (5th Supp.) (the “Act”), as amended to the date hereof.
Dear XXXXXXXXXX:
We are writing in reply to your inquiry of October 15, 2025 in which you requested our views on whether an online marketplace for event tickets is a “platform” as defined under subsection 282(1) of the Act. More specifically, you inquired whether such a marketplace connects sellers to other users “for the provision of relevant services or the sale of goods”, one of the conditions to being a “platform”.
Your letter described the following situation:
1. The taxpayer is based in the United States and Canada and operates an online marketplace platform (the “Marketplace”) that connects sellers of event tickets, such as concerts, sports games, and theater performances, with buyers.
2. Acting as an intermediary, the platform enables third-party sellers to list tickets and allows buyers to browse and purchase them. The taxpayer does not own the tickets. Instead, it provides the infrastructure and services that facilitate these transactions.
3. The taxpayer develops, owns, and maintains the core technology, including mobile apps, website infrastructure, data analytics, fraud prevention tools, and the group’s brands and trademarks.
4. Operating exclusively as a secondary ticket marketplace, the platform features tickets managed by professional resellers or pre-screened individual sellers. It does not sell primary tickets.
5. Revenue is earned through service and delivery fees charged to buyers upon successful transactions.
6. Additional services include a rewards program, customer support, and guarantees ensuring ticket authenticity and timely delivery.
7. Payments are handled by third-party processors. Buyers pay the listed price plus applicable fees and taxes, while sellers receive payment net of marketplace fees after order fulfillment and risk checks.
8. Ticket delivery is primarily electronic, via mobile or print-at-home formats, with limited physical shipping through third-party carriers.
9. The majority of buyers and sellers are located in the United States and Canada, with some international activity.
For clarity and to narrow down the scope of this interpretation request, we made the following assumptions:
1. The taxpayer is an “entity” as defined in subsection 282(1);
2. The Marketplace is a software, including a website or a part of it and applications, including mobile applications;
3. The Marketplace is accessible by users and allows users that are resellers of event tickets to be connected to other users that are buyers;
4. None of the exceptions contained in paragraphs (a) to (c) of the “platform” definition in subsection 282(1) is applicable to the Marketplace;
5. The Marketplace does not facilitate the rental of real or immovable property or the rental of a means of transport; and
6. Vendors on the Marketplace are not employed by the taxpayer or related entities (as defined in subsection 270(1)) of the taxpayer.
Our comments
To determine whether an entity has potential reporting requirements in Canada under Part XX, the first step is to determine whether there is a “platform”, as defined in subsection 282(1).
A determination of whether an online marketplace is a “platform” depends on the particular facts and circumstances of each case. As noted in IC70-6R12 – Advance Income Tax Rulings and Technical Interpretations at paragraph 7, where the issue is primarily a factual or legal determination, the Income Tax Rulings Directorate will not issue a technical interpretation. Although we cannot provide a determination of whether the Marketplace is a “platform”, we offer the following comments that may be of assistance.
Subsection 282(1) defines “platform” as follows [emphasis added]:
“platform” means a software, including a website or a part of it and applications, including mobile applications, accessible by users and allowing sellers to be connected to other users for the provision of relevant services or the sale of goods, directly or indirectly, to such users (including the collection and payment of consideration in respect of relevant activities), but does not include, in the provision of relevant services or the sale of goods, software exclusively allowing without any further intervention
(a) the processing of payments in relation to relevant activities;
(b) listing or advertising in relation to relevant activities; or
(c) redirecting or transferring of users to a platform.
As noted in your inquiry, the central question is whether the Marketplace connects sellers to other users “for the provision of relevant services or the sale of goods”, and as a result satisfies the conditions to be considered a “platform”.
Relevant Services
“Relevant service” is defined in subsection 282(1) to mean, if provided for consideration, the rental of real or immovable property, a personal service, the rental of a means of transport, or a prescribed service. According to the facts of your request, the Marketplace does not facilitate the rental of real or immovable property or the rental of a means of transport. In addition, there is no prescribed service to date. That leaves us only “personal service” to consider.
“Personal service” is defined in subsection 282(1), as follows [emphasis added]:
“personal service” means a service involving time- or task-based work performed by one or more individuals at the request of a user, unless such work is purely ancillary to the overall transaction, but does not include a service provided by a seller pursuant to an employment relationship with the platform operator or a “related entity” (as defined in subsection 270(1)) of the platform operator.
To ascertain whether an online marketplace facilitates the provision of personal services, we considered the typical work performed by a vendor (or individuals engaged by a vendor) in the process of selling an event ticket on the marketplace. It is clear that being a vendor on such a marketplace will involve some time- or task-based work on the vendor’s part, for example, registering for an account on the marketplace, complying with the pre-screening procedures required by the marketplace, or listing ticket inventory on the marketplace. In our view, this type of work is not carried out following a specific user request and therefore are not personal services.
On the other hand, we expect the vendor will perform some time- or task-based work at the request of a user, such as fulfilling an order by e-mailing an electronic ticket or physically mailing a paper ticket to the buyer. While this activity is carried out following a user’s (the buyer’s) request, we are of the view that the vendor’s time and labour spent on this work is purely ancillary to the overall transaction of sale of the ticket and therefore also not personal services.
Further, we considered whether such a marketplace can be viewed as facilitating the provision of personal service by individuals other than the vendor or individuals engaged by the vendor. Arguably, an event ticket entitles its holder to enjoy a service involving time- and task-based work performed by the event organizers (e.g., promoters, artists, athletes, crew members, venue staff). Nevertheless, to be a personal service, it must be performed at the request of a particular user or set of users of the platform. Concerts and sport events are organized at the discretion of the organizer. The organizer decides whether to hold the event at all, and if so, the date, time, and location of the event; the events are not adapted to the specific time or content requirement of any user of an online marketplace that sells their tickets. In our view, events such as concerts and sport games that are pre-scheduled and non-customizable are not personal services.
In the scenario where an online marketplace allows users to browse and request professional ticket resellers to search their networks for tickets to a particular rare or sold-out event, essentially, a white-glove or concierge ticket hunting service, we may consider such a service to be a “personal service” because it is carried out at a user’s request.
Sale of Goods
“Goods” is defined in subsection 282(1), as follows:
“goods” means any tangible property or, for civil law, any corporeal property.
In our view, a ticket in an electronic format (e.g., a QR code) is clearly not a tangible property due to the lack of physical existence. While a paper ticket, or an electronic ticket printed on paper, is a physical object one can touch, the paper itself generally only functions as evidence of the underlying contractual right to attend an event and does not have value independent of this right. As such, where the transaction is, in substance, a transfer of an intangible contractual right to attend an event (whether evidenced by paper or electronically), the Marketplace may be viewed as facilitating the transfer of an intangible right rather than the sale of “goods” for the purposes of Part XX.
In the scenario where physical tickets for past events are sold on an online marketplace for its collectible value as a memorabilia rather than its underlying right to attend the event, it is arguable that such tickets can be viewed as tangible properties, or “goods”.
Accordingly, it is unlikely that an online marketplace for event tickets, as described in your enquiry, is a “platform” as defined under subsection 282(1) of the Act. Although it is a question of fact, such a marketplace does not appear to facilitate the provision of relevant services, specifically, personal services, and ordinary event tickets in both physical and electronic formats are intangible properties and not goods.
We trust these comments will be of assistance.
Yours truly,
Sophie Larochelle
Acting Director
Specialty Tax Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch
All rights reserved. Permission is granted to electronically copy and to print in hard copy for internal use only. No part of this information may be reproduced, modified, transmitted or redistributed in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, or stored in a retrieval system for any purpose other than noted above (including sales), without prior written permission of Canada Revenue Agency, Ottawa, Ontario K1A 0L5
© His Majesty the King in Right of Canada, 2026
Tous droits réservés. Il est permis de copier sous forme électronique ou d'imprimer pour un usage interne seulement. Toutefois, il est interdit de reproduire, de modifier, de transmettre ou de redistributer de l'information, sous quelque forme ou par quelque moyen que ce soit, de facon électronique, méchanique, photocopies ou autre, ou par stockage dans des systèmes d'extraction ou pour tout usage autre que ceux susmentionnés (incluant pour fin commerciale), sans l'autorisation écrite préalable de l'Agence du revenu du Canada, Ottawa, Ontario K1A 0L5.
© Sa Majesté le Roi du Chef du Canada, 2026
Email this Content