Conference example
ABC Co hosts a two day conference on the latest developments within a particular field and engages various experts to present papers and lead workshops at the conference. The conference is open to any individual that would like to attend. The fee is paid by the individual or the individual's employer.
ABC Co supplies a two day training session for employees of XYZ Co on the latest developments within a particular field. ABC Co is engaged by and paid by XYZ Co directly to develop and deliver the content for the training session.
How does s. 17 (personal services) and s. 28 (services in relation to a location specific event) apply? CRA responded:
The provision of the right to attend a professional development conference, workshop, seminar, or training session, would…generally be considered to be a supply of intangible personal property… . The place of supply rules in sections 6 and 7…would generally be relevant… .
… Generally, to determine that a particular supply is a service, it would have to be established based on a complete set of facts that the predominant element of the supply is a service… .
…[T]o be considered a service in relation to a location-specific event for purposes of section 28…the event must be the object of the service. Generally, this would include services supplied to an organizer of an event such as event planning or the performance of the event.
