CRA finds that a non-resident cruise ship stopping at Canadian ports was carrying on business in Canada

A non-resident cruise line company sells cruises (including cruises with stops at Canadian ports) to customers around the world, including sales in Canada through independent third-party Canadian sales agents, and does not have a presence in Canada otherwise than through its ships (e.g., its only employees in Canada are crew members). CRA found that the company was carrying on business in Canada. CRA provided an example of a ship with 3,000 customers accompanied by 1,275 employees, with such employees working a total of 10 days in Canada. It stated that, in this light, the activities carried on in Canada were significant and related to the company’s main business line. Furthermore, there was the extensive marketing in Canada.

Neal Armstrong. Summary of 10 August 2023 GST/HST Interpretation 183417 under ETA s. 240(1).