Words and Phrases - "advertising"

a
88
b
44
c
78
d
52
e
38
f
31
g
19
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
76
s
90
t
47
u
16
v
9
w
23
y
2

8 December 2022 GST/HST Interpretation 222719 - Supplies of digital marketing services made to a non-resident

Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 8
digital marketing services were not zero-rated

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

CRA ruled that such services were not zero-rated under Sched. VI, Pt. V, s. 8 as supplies of a service of advertising made to an unregistered non-resident person, stating:

[A]s described in … Memorandum 4-5-3 … the CRA generally considers an advertising service to be:

(a) a service of creating a message oriented towards soliciting business, attracting donations, or calling public attention in the form of an information notice, a political announcement or other similar communication by any means including oral, written, or graphic statements and representations disseminated by any means, including,

(i) in a newspaper or other publication,

(ii) on radio or television,

(iii) in a notice, handbill, sign, catalogue, or letter, and

(iv) on a billboard or on real property; and

(b) a service directly related to the communication of such a message (e.g., air time on a broadcasting service, space in a publication) where,

(i) the communication service is supplied as part of the supply of a message as defined in paragraph (a) above, or

(ii) the person providing the communication service can demonstrate that, at the time the supply is made, the service is in relation to the supply of a message as defined in paragraph (a) above.

[Y]ou do not create the written digital content for [NRCo]’s clients and are not involved in posting the Ads on the social media platform. You are essentially providing advice on creating high quality social media content and marketing plan. … [CanCo] is not providing a service of creating a set specific advertising message, within the meaning of an advertising service as described under paragraph (a) above. The supply is also not considered to be a service directly related to the communication of a message; therefore, paragraph (b) above does not apply.

However, it noted that such services might be zero-rated under Sched. VI, Pt. V, s. 7 or s. 23.

Words and Phrases
advertising
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 7 meaning of advisory service 222
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 23 meaning of professional service 204