CRA indicates that digital marketing services were not zero-rated

A resident registrant (CanCo) provided, to non-resident clients from a location in Canada, digital advertising, digital marketing, content marketing strategy and social media services.

CRA ruled that such services were not zero-rated under ETA Sched. VI, Pt. V, s. 8 as supplies of an advertising service made to an unregistered non-resident person, given that those services did not themselves entail creating advertising messages, and did not directly relate to communicating such messages. However, it noted that such services might be zero-rated under Sched. VI, Pt. V, s. 7 or s. 23 (the more general provisions for services or professional services).

Neal Armstrong. Summary of 8 December 2022 GST/HST Interpretation 222719 under ETA Sched. VI, Pt. V, s. 8, s. 7 and s. 23.