Words and Phrases - "professional service"

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. Regarding s. 23, it stated:

A professional service is generally defined in terms of the individual providing the service and refers to a service provided by an individual whose vocation or occupation requires special, usually advanced, education and skills. For purposes of section 23 of Part V of Schedule VI, the service may be provided by a member of a professional association, a professional corporation or a similar body, which is recognized by a statute in at least one province or territory or by one federal body, and which enforces standards of professional practice as well as a code of ethics.