CRA states that services are re tangible personal property for HST place-of-supply purposes if they “serve a particular need…relating to the property”

Although, the HST rules for determining the province in which a service is supplied generally look to the address of the recipient, the place of supply of services in relation to tangible personal property is generally the province where the TPP is situate (unless it moves around, in which case there generally is reference to the province of primary performance). In the course of explaining a heavily redacted ruling, CRA stated:

[W]hether a service is considered to be in relation to TPP depends on whether there is a direct connection between the service and the property, taking into account the objectives of the service and the particular circumstances of each case. With respect to determining the objectives of the service, it must be determined whether the service is designed, developed or undertaken to fulfill or serve a particular need or requirement arising from or relating to the property. It must then be determined whether the relationship between the purpose or objective of the service and the property is direct rather than merely indirect.

Hope that helps.

Neal Armstrong. Summary of 16 March 2016 Ruling 158766 under New Harmonized Value-Added Tax System Regulations, s. 15.