GST/HST place of supply: goods go by delivery, services by address

Asked of Whizi's Canadian CPA agent. Every figure is checked against canada.ca and the Income Tax Act.

Canadian CPA

How do the GST/HST place of supply rules decide which rate I charge a client in another province?

Canadian CPA

In 2026, the GST/HST place of supply rules tax goods at the rate of the province where you deliver them, and services at the rate of the client's Canadian home or business address you obtain. The rates are 13% HST in Ontario, 14% in Nova Scotia, 15% in the other HST provinces and 5% GST elsewhere.

Which rule sets the province for each kind of supply?

The place of supply rules decide which province a taxable supply made in Canada is made in, and that province sets the rate. Check for a specific rule first; the general rule only applies when no specific rule does canada.ca. The legal source is section 144.1 and Schedule IX of the Excise Tax Act, plus Part 1 of the HST place of supply regulations (SOR/2010-117) laws-lois.justice.gc.ca.

SupplyProvince of supplyCRA example
Goods soldWhere you deliver or make them available, or where you ship, mail or courier themAlberta store ships to Ontario: 13% HST
Goods leased over 3 monthsOrdinary location of the goods for each lease intervalCopier moves from NB to Manitoba: GST from that interval
Real propertyWhere the property is locatedNB warehouse sold to a Saskatchewan buyer: NB rate
Services (general rule)Client home or business address in Canada you obtainQuebec web designer, Ontario client: Ontario rate
Services, no address obtainedWhere the Canadian part of the work is primarily performedAlberta firm, no client address: 5% GST
Personal services (90% or more in the client's presence)Where the service is performedHaircut in Fredericton: NB rate
Services related to real propertyWhere the property is located, by physical sizeLandscaping 40% AB, 35% PEI, 25% ON: PEI rate
Repairs to goodsWhere you deliver the goods back after the workComputer fixed in Quebec, shipped to Ontario: Ontario rate
Freight transportationDestination province
Litigation servicesProvince where the litigation takes placeKenora lawyer for a Manitoba driver: Ontario rate
Intangible personal propertyWhere it can be used, then the client addressSoftware usable only at an Ontario office: Ontario rate

Every row comes from the CRA's place of supply page canada.ca. The CRA lists the HST at 13% in Ontario, 14% in Nova Scotia and 15% in New Brunswick, Newfoundland and Labrador and Prince Edward Island, with 5% GST in every other province and territory canada.ca. For the full rate table, and the PST that sits on top of the 5% GST in some provinces, see HST rates by province for 2026. Quebec is a GST province for these rules, so the GST at 5% applies there, and Revenu Québec handles GST/HST rulings for Quebec businesses canada.ca.

How does the address rule pick the province for a service?

General rule 1 looks at the client's address in Canada that you obtain in the ordinary course of your business. One home or business address: that province. Several: the one most closely connected with the supply. No home or business address, but some other Canadian address: the one most closely connected with the supply laws-lois.justice.gc.ca.

The CRA's April 2026 memorandum fills in the detail. The address has to be a physical location, so an email or IP address doesn't count. A PO Box isn't a business address, but it can still be "another address" under the fallback. When a client has several addresses, the one the client contracts from is generally the most closely connected, and you can't simply pick the lowest rate. In the CRA's example a client with an Ontario head office and an Alberta payables address, contracting from Ontario, is charged 13% canada.ca.

General rule 2 applies only when you obtain no Canadian address. If more than 50% of the Canadian part of the service is performed in HST provinces, the supply is made in the HST province where the most work is done; otherwise it's a GST supply. A tie between HST provinces goes to the highest rate, so work split 50% Ontario and 50% Nova Scotia is taxed at 14% canada.ca. If the tied provinces share a rate, such as New Brunswick and PEI at 15%, section 18 sends the supply to the province of your most closely connected business address, or the nearest tied province laws-lois.justice.gc.ca.

What does an Ontario firm charge clients at four different addresses?

Your client is an Ontario accounting firm that bills a $10,000 advisory fee to four clients. Advisory work isn't a personal service, so the general address rule applies, and each client's business address on file sets the rate. The firm's own Ontario office doesn't matter.

Client business addressRateTax on $10,000Invoice total
Toronto, Ontario13% HST$1,300$11,300
Halifax, Nova Scotia14% HST$1,400$11,400
Moncton, New Brunswick15% HST$1,500$11,500
Calgary, Alberta5% GST$500$10,500

Charge the Calgary client 13% and the firm has overcharged by $800; charge the Halifax client 13% and it has undercollected $100 that it still owes. The address rule turns on what you obtain, not where the work is done canada.ca.

Where are goods treated as delivered?

For a sale of goods, the province is where you deliver them or make them available to the buyer. If you mail or courier them, or hand them to a carrier for a destination, it's the destination province. The CRA's example is an Alberta store with legal delivery in Alberta that ships the goods to Ontario: that's an Ontario supply at 13% HST canada.ca. On a $2,000 order, that's $260 of HST instead of $100 of GST.

The goods rules have their own exceptions. A specified motor vehicle can be supplied in the province where it's registered. A lease over three months is a series of supplies, one per lease interval, each taxed where the goods are ordinarily located for that interval, so a photocopier that moves from New Brunswick to Manitoba drops to the GST rate from that interval. A rental of three months or less follows the delivery rules canada.ca.

Which province does intangible personal property belong to?

Licences, passes and other intangible personal property start with where the rights can be used. If they can only be used primarily (more than 50%) in GST provinces, it's a GST supply. If they can only be used primarily in HST provinces, the supply is made in the HST province with the largest share of use canada.ca.

When use isn't limited that way, three fallbacks apply in order. For consideration of $300 or less sold in person at your permanent establishment or vending machine, the province of that location. Otherwise, the client address in Canada you obtain, if the property can be used there. Otherwise, the HST province with the highest rate where the property can be used canada.ca.

When does your client self assess the provincial part of the HST?

A supply taxed at 5% can still cost your client HST. A resident of an HST province who buys a service or intangible made in a GST province, or in a lower rate HST province, and uses 10% or more of it in the higher rate province generally self assesses the difference canada.ca. The same applies to goods brought into a higher rate province. A registrant using the property or service 90% or more in commercial activities is exempt, and no self assessment is needed when the monthly total is under $25.

Registrants report the self assessed amount on line 405 of the GST/HST return; others use Form GST489. If the provincial part was paid and the property or service ends up used in another province, the rebate is on Form GST495 for goods or GST189 with reason code 13 for services and intangibles canada.ca. The line itself is covered in GST/HST return lines.

Does my client charge the HST rate of their own province on services?

Canadian CPA

No. Under the general rule the client's customer address sets the rate, so an Ontario supplier charges 5% GST to a client whose only business address is in Alberta. The supplier's location only matters through performance when no address is obtained, or in the section 18 tie rule canada.ca.

What if the client only gives an email address?

Canadian CPA

Then you haven't obtained an address for rule 1, because an email or IP address isn't a physical location. You move to rule 2 and tax the service where the Canadian part of the work is primarily performed canada.ca.

What happens when a client on a monthly retainer moves to another province?

Canadian CPA

Each billing period of an ongoing service is a separate supply under subsection 136.1(2) of the Excise Tax Act, so the place of supply is tested again each period and can change when the address you hold changes canada.ca.

Do these rules decide whether a supply is zero rated?

Canadian CPA

No. They only pick the province for a taxable supply made in Canada. A zero rated supply is taxed at 0% wherever it is made, which is covered in GST/HST zero rated supplies.

General information for the tax year shown, not advice for a specific client. Confirm the facts before you file or remit.

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