6 April 1990 T.I. (September 1990 Access Letter, ¶1441)

In order for payments for software services provided by the supplier of the software not to be considered payment in connection with the use of the computer software, the acquisition of the services should be optional, and the payments therefor should be reasonable in relation to the software licence fee. Computer software updates represent modifications, improvements and additions to the software originally licenced and therefore are subject to Part XIII tax rather than being regarded as payments for services.

Where the service of a non-resident is the providing of information or advice by way of a telephone or electronic mail hotline and where the non-resident so providing such information or advice is not in Canada, the service will not be considered to be rendered in Canada. The shipping of materials from the United States and the giving of maintenance instructions via a telephone line also would be exempt on the same grounds.