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Place of Supply in a Province – Transportation

GST/HST Memorandum 3-3-7
April 2026

This memorandum cancels and replaces, Draft GST/HST Technical Information Bulletin B-103, Harmonized Sales Tax – Place of supply rules for determining whether a supply is made in a province.

This memorandum explains the place of supply rules included in Schedule IX of the Excise Tax Act (ETA) and in the New Harmonized Value-added Tax System Regulations that determine whether certain transportation related supplies made in Canada are made in a participating province and consequently subject to the provincial part of the HST in addition to the federal part of the HST.

This memorandum does not provide detailed information about the new digital economy measures applicable to digital economy businesses including businesses that are registered or required to be registered under the simplified GST/HST registration regime of Subdivision E of Division II of Part IX of the ETA, and to platform operators and non-resident digital economy businesses that are registered or required to be registered under the regular GST/HST registration regime. For more information, go to GST/HST for digital economy businesses: Overview or call the Canada Revenue Agency (CRA) at 1‑833‑585‑1463 (from Canada and the U.S.) or 1‑613‑221‑3154 (from elsewhere – collect calls are accepted.)

The following other memoranda in this series describe in detail the provincial place of supply rules for specific taxable supplies:

Except as otherwise noted, all statutory references in this publication are to the provisions of the Excise Tax Act (ETA), and all references to the Regulations are to the New Harmonized Value-added Tax System Regulations. The information in this publication does not replace the law found in the ETA and its regulations.

If this information does not completely address your particular situation, you may wish to refer to the ETA or relevant regulation, or call GST/HST Rulings at 1‑800‑959‑8287 for additional information. If you require certainty with respect to any particular GST/HST matter, you may request a ruling. GST/HST Memorandum 1-4, Requesting a GST/HST Ruling or Interpretation, explains how to obtain a ruling or an interpretation.

If you are located in Quebec and wish to request a ruling related to the GST/HST, please call Revenu Québec at 1‑800‑567‑4692. You may also visit the Revenu Québec website at revenuquebec.ca to obtain general information.

For listed financial institutions that are selected listed financial institutions (SLFIs) for GST/HST or Quebec sales tax (QST) purposes or both, whether or not they are located in Quebec, the CRA administers the GST/HST and the QST. If you wish to make a technical GST/HST or QST enquiry related to SLFIs, please call 1‑855‑666‑5166.

GST/HST rates

Reference in this publication is made to supplies that are subject to the GST or the HST. The GST/HST rates are those that were in effect at the time of publishing. For the list of all applicable GST/HST rates (current and historic), go to GST/HST calculator (and rates).

If you are uncertain as to whether a supply is made in a participating province, refer to GST/HST Memorandum 3-3-2, Place of Supply in a Province – Overview.

Table of Contents

General

1. Taxable supplies of property or services that are made in Canada are generally subject to the GST (the federal part of the HST) under subsection 165(1) at a rate of 5%. In addition, taxable supplies that are made in a participating province are subject to the provincial part of the HST under subsection 165(2) at the provincial rate for the province, which results in the application of the HST at the relevant harmonized rate.

2. In the case of a taxable supply that is made in Canada, it is necessary to determine the province where the supply is made in order to apply the applicable tax and rate. Provincial place of supply rules exist for GST/HST purposes to determine the province in which a supply is deemed to be made.

3. Generally, the place of supply rules described in Chapter 3 of the GST/HST Memoranda Series are also used to determine if the First Nations goods and services tax (FNGST) applies to supplies where a First Nation or an Indigenous government has imposed the FNGST. For more information, refer to paragraphs 51 to 57 of this memorandum.

4. For further information regarding the legislative framework as well as the issues to consider before applying the provincial place of supply rules, please refer to GST/HST Memorandum 3-3-2, Provincial Place of Supply - Overview.

5. Unless otherwise indicated, all references to supplies are to taxable (other than zero-rated) supplies made in Canada.

6. References in this memorandum to terms, concepts and examples are made in the context of the provincial place of supply rules for persons registered under Subdivision D of Division V of Part IX of the ETA (the regular GST/HST regime).

7. The rules explained in this memorandum do not apply to supplies of digital property or services made or facilitated by persons registered under the digital economy provisions of Subdivision E of Division II of Part IX of the ETA (simplified GST/HST registration). Subdivision E contains separate registration and place of supply rules for distribution platform operators and non-resident suppliers of digital property and services. For additional information on the digital economy provisions, go to GST/HST for digital economy businesses: Overview.

8. The Canada Revenue Agency (CRA) generally does not administer provincial taxes, duties or fees imposed by provincial legislation, other than the QST for persons that are selected listed financial institutions (SLFIs) for GST/HST or QST purposes or both. To determine whether any provincial taxes, duties or fees are applicable in respect of a supply (for example, the QST in Quebec for persons that are not SLFIs), contact the appropriate provincial taxation authority.

Supply of passenger transportation

9. The general place of supply rules for services are subject to specific place of supply rules that may apply to certain supplies of passenger transportation services.

10. Where the specific place of supply rules do not determine the place of supply of the passenger transportation service because the conditions for the application of those rules are not met, it is the general place of supply rules for services that will determine the place of supply of the service. These general place of supply rules are discussed in GST/HST Memorandum 3-3-6, Place of Supply in a Province – General Rules for Services.

11. The place of supply of a passenger transportation pass is not discussed in this memorandum. For more information, refer to the specific place of supply rules for a passenger transportation pass in GST/HST Memorandum 3-3-5-1, Place of Supply in a Province – Specific Rules for Intangible Personal Property.

Defined terms

12. The following terms are defined in section 1 of Part VII of Schedule VI, section 1 of Part VI of Schedule IX and section 20 of the Regulations.

13. A continuous journey of an individual or a group of individuals is defined in section 1 of Part VII of Schedule VI and section 1 of Part VI of Schedule IX to mean "the set of all passenger transportation services provided to the individual or group

14. The origin of a continuous journey is defined in section 1 of Part VII of Schedule VI, section 1 of Part VI of Schedule IX and section 20 of the Regulations to mean the place where the passenger transportation service that is included in the continuous journey and that is first provided begins.

15. The leg of a journey on a conveyance is defined in section 1 of Part VI of Schedule IX and section 20 of the Regulations to mean "a part of the journey that begins where passengers embark or disembark the conveyance or where it is stopped to allow for its servicing or refuelling and ends where it is next stopped for any of those purposes".

16. A stopover, in respect of a continuous journey of an individual or a group of individuals, is defined in section 1 of Part VII of Schedule VI, section 1 of Part VI of Schedule IX and section 20 of the Regulations to mean any place at which the individual or group embarks or disembarks a conveyance used in the provision of a passenger transportation service included in the continuous journey, for any reason other than transferring to another conveyance or to allow for servicing or refuelling of the conveyance.

17. However, for purposes of determining the place of supply in a province in the case of a continuous journey of an individual or group of individuals that does not include transportation by air and the origin and termination of which are in Canada, section 1 of Part VI of Schedule IX and section 20 of the Regulations provide that a stopover does not include any place outside Canada where, at the time the journey begins, the individual or group is not scheduled to be outside Canada for an uninterrupted period of at least 24 hours during the course of the journey.

18. The termination of a continuous journey is defined in section 1 of Part VII of Schedule VI, section 1 of Part VI of Schedule IX and section 20 of the Regulations to mean "the place where the passenger transportation service that is included in the continuous journey and that is last provided ends".

Passenger transportation services

19. Section 21 of the Regulations provides the place of supply rules for passenger transportation services. Under paragraph 21(a) of the Regulations, the supply of a passenger transportation service is made in a participating province if one of the following applies:

20. Pursuant to paragraph 21(b) of the Regulations, the supply of a passenger transportation service is made in a non-participating province if one of the following applies:

Example 1 – Origin in a participating province

An individual purchases round-trip air passenger transportation from Moncton, New Brunswick to Montréal, Quebec. The ticket issued for the passenger transportation specifies Moncton as the origin of the continuous journey.

The ticket issued in respect of the passenger transportation service that is provided first and included in the continuous journey specifies the origin of the continuous journey as being in New Brunswick and there is no termination or stopover outside Canada.

The supply of the passenger transportation service is therefore made in New Brunswick and is subject to the HST at a rate of 15%.

Example 2 – Origin in a participating province with a stopover outside Canada

An individual purchases round-trip air passenger transportation from Halifax, Nova Scotia to Boston, USA. Halifax is specified as the origin of the continuous journey on the ticket.

Although the ticket issued in respect of the passenger transportation service that is provided first and included in the continuous journey specifies that the origin of the continuous journey is in Nova Scotia, there is a stopover outside Canada.

The supply of the passenger transportation service is therefore made in a non-participating province and is subject to the GST at a rate of 5%.

Example 3 – Origin in a participating province with a termination outside Canada

An individual purchases a ticket for a flight from Toronto, Ontario to London, England. The ticket issued for the flight specifies Toronto as the origin of the continuous journey.

The ticket issued in respect of the passenger transportation service that is provided first and included in the continuous journey specifies that the origin of the continuous journey is in Ontario, but the termination of the continuous journey is outside Canada.

Although the supply of the passenger transportation service is therefore made in a non-participating province, the supply is zero‑rated under section 3 of Part VII of Schedule VI because the termination of the continuous journey is outside the taxation area.

For further information regarding zero-rated passenger transportation services and the meaning of taxation area, refer to GST/HST Memorandum 28-3, Passenger Transportation Services.

Example 4 – Ticket specifies the origin

A resident of Ontario purchases a booklet of 10 tickets for round-trip rail passenger transportation from Toronto, Ontario to Montréal, Quebec. The tickets specify Toronto as the origin of each trip.

The tickets issued in respect of the passenger transportation service that is provided first and included in the continuous journey specifies that the origin of the continuous journey is in Ontario and any stopovers and terminations are in Canada.

The supplies of the passenger transportation services are therefore made in Ontario and are subject to the HST at a rate of 13%.

Tangible personal property and services supplied during passenger transportation services

Supplies made during an international flight or international voyage

21. Under section 180.1, a supply of tangible personal property or a service (other than a passenger transportation service) is deemed to be made outside Canada and is therefore not subject to tax where both conditions are met:

22. An international flight is defined in subsection 180.1(1) to mean "any flight (other than a flight originating and terminating in Canada) of an aircraft that is operated by a person in the course of a business of supplying passenger transportation services".

23. An international voyage is defined in subsection 180.1(1) to mean "any voyage (other than a voyage originating and terminating in Canada) of a vessel that is operated by a person in the course of a business of supplying passenger transportation services".

Example 5 – Supply made during an international flight

An individual purchases round-trip air passenger transportation from Halifax, Nova Scotia to Boston, USA. The individual purchases a sandwich during the flight from Halifax to Boston and another one during the return flight from Boston to Halifax.

The supply of the sandwich on each flight is deemed to be made outside Canada because each supply is made during an international flight. As a result, the supplies are not subject to tax.

Property and services supplied during passenger transportation services

24. Under section 23 of the Regulations, if a supply of property or a service (other than a passenger transportation service) is made to an individual on board a conveyance in the course of a business of supplying passenger transportation services and the property or service is delivered, performed or made available on board the conveyance during any leg of the journey that begins in any province and ends in any province, the supply of the property or service is made in the province in which that leg of the journey begins.

Example 6 – Property delivered during a leg of a journey

On a flight from Ottawa, Ontario to Vancouver, British Columbia, by way of Calgary, Alberta, a passenger purchases a beverage during the leg of the journey that begins in Ottawa and another one during the leg of the journey that begins in Calgary.

The first beverage was delivered during the leg of the journey that begins in Ontario. The supply of the first beverage is therefore made in Ontario and is subject to the HST at a rate of 13%.

The second beverage was delivered during the leg of the journey that begins in Alberta. The supply of the second beverage is made in Alberta, which is a non-participating province, and is therefore subject to the GST at a rate of 5%.

Services related to the supply of passenger transportation services

Baggage charges

25. Under section 4 of Part VI of Schedule IX, a supply of a service of transporting an individual's baggage by a supplier of a passenger transportation service made in connection with the passenger transportation service is made in the same province in which the supply of the passenger transportation service is made.

Example 7 – Supply made in the same province as supply of passenger transportation service

An airline supplies a domestic air passenger transportation service from Vancouver, British Columbia to St. John's, Newfoundland and Labrador. In connection with that supply, the airline charges a baggage fee to an individual for each checked bag.

The supply of the baggage service is made in the same province as the passenger transportation service. The supply of the passenger transportation service is made in a non-participating province because the journey originates in British Columbia, which is a non-participating province.

The supply of the baggage service is therefore also made in a non-participating province and is subject to the GST at a rate of 5%.

Child supervision

26. Under section 4 of Part VI of Schedule IX, a supply of a service of supervising an unaccompanied child by a supplier of a passenger transportation service made in connection with the passenger transportation service is made in the same province in which the supply of the passenger transportation service is made.

Example 8 – Supply made in the same province where passenger transportation service was made

An airline supplies a domestic passenger transportation service from Charlottetown, Prince Edward Island to Montréal, Quebec. In connection with that supply, the airline supplies the service of supervising an unaccompanied child.

The supply of the service of supervising the unaccompanied child is made in the same province as the passenger transportation service. The supply of the passenger transportation service is made in Prince Edward Island, which is a participating province, because the journey originates in Prince Edward Island.

The supply of the service of supervising the unaccompanied child is therefore also made in Prince Edward Island and is subject to the HST at a rate of 15%.

Services related to a ticket, voucher, or reservation

27. Under section 4.1 of Part VI of Schedule IX, a supply, made by a supplier of a passenger transportation service, of a service of issuing, delivering, amending, replacing or cancelling a ticket, voucher, or reservation for the passenger transportation service is made in the same province in which the original supply of the passenger transportation service would be made, if it were completed in accordance with the agreement for that supply.

Example 9 – Supply made in the same province where passenger transportation service would be made

An individual is charged a service fee for cancelling a ticket for round-trip air passenger transportation from Ottawa, Ontario to Regina, Saskatchewan that specifies Ottawa as the origin of the continuous journey.

The supply of the service of cancelling the ticket is made in the same province as the passenger transportation service for which the ticket was issued. Because the origin of the journey would have been in Ontario, the passenger transportation service would have been supplied in Ontario.

The supply of the service of cancelling the ticket is therefore made in Ontario and is subject to the HST at a rate of 13%.

Freight transportation services

28. The general place of supply rules for services are subject to specific place of supply rules that may apply to certain supplies of freight transportation services.

29. If a service does not meet the definition of freight transportation service as explained in paragraphs 30 and 31 of this memorandum, the specific place of supply rule for freight transportation services does not apply. Depending on the nature of the particular service, the place of supply of the service would be determined using the rules for services in GST/HST Memorandum 3-3-6, GST/HST Memorandum 3-3-6-1, Place of Supply in a Province – Personal Services, Services in Relation to Property and Telecommunication Services, or GST/HST Memorandum 3-3-6-2, Place of Supply in a Province – Specific rules for Services – Special Cases.

Defined terms

30. A freight transportation service is defined in section 1 of Part VII of Schedule VI and section 1 of Part VI of Schedule IX to mean, in part, "a particular service of transporting tangible personal property [which includes money for purposes of freight transportation services] including

31. However, a freight transportation service does not include a service provided by the supplier of a passenger transportation service of transporting an individual's baggage in connection with the passenger transportation service. For more information, refer to paragraph 25 of this memorandum.

32. For place of supply purposes, the destination of a freight transportation service is defined in section 1 of Part VI of Schedule IX to mean "the place specified by the shipper of the property [usually on the bill of lading or other shipping documents] where possession of the property is transferred to the person to whom the property is consigned or addressed by the shipper".

Supply of freight transportation services

33. Under section 5 of Part VI of Schedule IX, a supply of a freight transportation service is made in a province if the destination of the service is in the province.

34. Special rules apply to most supplies of mail services supplied by the Canada Post Corporation. These rules are explained beginning at paragraph 43 of this memorandum.

Example 10 – Destination in a province

A Quebec manufacturer hires a carrier to transport products from its plant in Montréal, Quebec to a wholesaler in Toronto, Ontario.

The destination of the freight transportation service is in Ontario. Therefore, the supply of the freight transportation service is made in Ontario and is subject to HST at a rate of 13%.

Example 11 – Destination in a province

An individual hires a moving company to pick up their personal effects at their residence in Whitehorse, Yukon and to deliver them to a residence in Kingston, Ontario.

The destination of the freight transportation service is in Ontario. Therefore, the supply of the freight transportation service is made in Ontario and is subject to the HST at a rate of 13%.

Example 12 – Destination in a province with origin outside Canada

A manufacturer in British Columbia hires a carrier to transport products from the USA to a wholesaler in Nova Scotia.

The destination of the freight transportation service is in Nova Scotia. However, while the supply of the freight transportation service is made in Nova Scotia, the supply is zero‑rated under section 8 of Part VII of Schedule VI, because it originates outside Canada.

For more information regarding zero-rated freight transportation services, refer to GST/HST Memorandum 28-2, Freight Transportation Services.

Example 13 – Destination in a province

A manufacturer hires a carrier to transport products from its plant in Fredericton, New Brunswick to a wholesaler in Sherbrooke, Quebec.

The destination of the freight transportation service is in Quebec. Therefore, the supply of the freight transportation service is made in Quebec, which is a non-participating province, and is subject to the GST at a rate of 5%.

Freight transportation service with a destination in more than one province

35. Under section 136.3, where a supply of a freight transportation service has destinations in more than one province, the provision of the service of transporting the goods destined for each province is deemed to be a separate supply made for separate consideration equal to the portion of the total consideration for the supply that is reasonably attributable to the transportation of the goods to that province. Therefore,

Example 14 – Deemed separate supplies for separate consideration

A computer manufacturer in Toronto, Ontario hires a carrier to transport computers to two different destinations. The manufacturer sold half of the load of computers to a company located in Ottawa, Ontario and the other half to a company in Montréal, Quebec. There is a single supply of a freight transportation service and a single charge for the service. Of the total, 40% is reasonably attributable to the transportation of the computers to Ottawa and 60% to Montréal.

The provision of the service of transporting the computers to the Ontario destination and the provision of the service of transporting the computers to the Quebec destination are each deemed to be separate supplies made for separate consideration.

The provision of the service of transporting the computers to the destination in Ontario is made in Ontario. The deemed consideration for this service is equal to 40% of the total charge and is subject to the HST at a rate of 13%.

The provision of the service of transporting the computers to the destination in Quebec is made in Quebec, which is a non-participating province. The deemed consideration for this service is equal to 60% of the total charge and is subject to the GST at a rate of 5%.

Postage and mail delivery services

36. Although the definition of freight transportation service includes a service of delivering mail, specific place of supply rules exist for mail delivery services that are evidenced by particular indicators of payment. Supplies of mail delivery services that are not evidenced by these particular indicators, or that do not meet other conditions in the specific place of supply rules, are subject to the place of supply rule for freight transportation services as explained in paragraphs 28 to 34 of this memorandum.

Defined terms

37. The following terms are defined under section 1 of Part VII of Schedule IX.

38. A postage stamp means "a stamp authorized by the Canada Post Corporation for use as evidence of the payment of postage, but does not include a postage meter impression, a permit imprint or any "business reply" indicia or item bearing that indicia."

39. A permit imprint means "an indicia the use of which as evidence of the payment of postage exclusively by a person is authorized under an agreement between the Canada Post Corporation and the person, but does not include a postage meter impression or any "business reply" indicia or item bearing that indicia."

Postage stamp and mail delivery service

40. Section 2 of Part VII of Schedule IX provides specific place of supply rules for the supply of a postage stamp or a postage-paid card, package or similar item (other than an item bearing a "business reply" indicia) and, where the stamp or item is used as evidence of the payment of postage for a mail delivery service, for the supply of the delivery service.

Postage stamp

41. Under section 2 of Part VII of Schedule IX, a supply of a postage stamp or a postage-paid card, package or similar item (other than an item bearing a "business reply" indicia) that is authorized by the Canada Post Corporation is made in the province in which the supplier delivers the stamp or item to the recipient of the supply.

42. Generally, tangible personal property (that is, a postage stamp, a postage paid card, a package or similar item) is considered to be delivered where its possession is transferred. However, for purposes of this rule, tangible personal property is also deemed to be delivered in a particular province, and not in any other province, if the supplier does either of the following:

Example 15 – Postage stamp delivered in person

An individual purchases several postage stamps at a retail postal outlet in Prince Edward Island to eventually use them to mail letters.

The individual takes delivery of the postage stamps in Prince Edward Island. Therefore, the supply of the stamps is made in Prince Edward Island and is subject to the HST at a rate of 15%.

Example 16 – Postage stamp delivered by mail

An individual in Winnipeg, Manitoba mail‑orders a booklet of postage stamps. The supplier delivers the booklet by mail from Halifax, Nova Scotia to the individual's address in Winnipeg, Manitoba.

The supplier delivered the stamps to the individual at an address in Manitoba. Therefore, the supply of the booklet of postage stamps is made in Manitoba, which is a non-participating province, and is subject to the GST at a rate of 5%.

Mail delivery service

43. Where a postage stamp or similar item is used as evidence of payment for a mail delivery service, section 2 of Part VII of Schedule IX provides that the supply of the service is made in the province in which the stamp or item is delivered. However, this rule does not apply in circumstances where either of the following apply:

44. In either of the cases outlined in paragraph 43 of this memorandum, the place of supply rule for freight transportation services, as explained in paragraphs 28 to 34 of this memorandum will apply to determine the place of supply of the mail delivery service. In such cases, the place of supply will therefore be determined by the destination of the mail delivery service.

Business indicia

45. Similarly, when an item bearing a "business reply" indicia is used, the place of supply rule for freight transportation services applies to determine the place of supply of the mail delivery service. As a result, the place of supply of a mail delivery service when a business reply indicia is used will be determined by the destination of the mail delivery service.

Example 17 – More than $5, address in a non-participating province

An individual in Halifax, Nova Scotia has a package to mail to an address in Regina, Saskatchewan. At a Canada Post retail outlet in Nova Scotia, the individual hands the addressed package to the clerk who attaches stamps totalling $10 to the package. There is no bill of lading.

Since the consideration for the supply of the mail delivery service is more than $5 and the address to which the package is sent is in a non-participating province, the place of supply rule regarding postage and mail delivery services is not applicable. The place of supply is instead determined in accordance with the rules for freight transportation services.

Because the package is sent to a destination in Saskatchewan, the supply of the service is therefore made in Saskatchewan, which is a non-participating province, and is subject to the GST at a rate of 5%.

Example 18 – More than $5, address in a participating province

An individual in Halifax, Nova Scotia has a package to mail to an address in Hamilton, Ontario. At a Canada Post retail outlet in Nova Scotia, the individual hands the addressed package to the clerk who attaches stamps totalling $10 to the package. There is no bill of lading.

Although the consideration for the supply of the mail delivery service is more than $5, the address to which the package is sent is in a participating province. As a result, the place of supply rule regarding postage and mail delivery services is applicable.

The postage stamps, which are used as evidence of the payment of postage for the mail delivery service, were delivered to the person in Nova Scotia. The supply of the mail delivery service is therefore made in Nova Scotia and is subject to the HST at 14%.

Example 19 – Less than $5

An individual in Fredericton, New Brunswick has a package to mail to an address in Winnipeg, Manitoba. At a Canada Post retail outlet in New Brunswick, the individual hands the addressed package to the clerk who attaches stamps totalling $4.50 to the package. There is no bill of lading.

Although the address to which the package is sent is in a non-participating province, the consideration for the supply of the mail delivery service is under $5.

As a result, the exclusion to the special place of supply rule for postal delivery does not apply, and the service is deemed to be made in the province where the stamps are delivered. The supply of the mail delivery service is therefore made in New Brunswick and is subject to the HST at 15%.

Postage meter

46. If the payment of postage for a mail delivery service that is supplied by the Canada Post Corporation, otherwise than under a bill of lading, is evidenced by a postage meter impression printed by a meter, section 3 of Part VII of Schedule IX deems the supply of the service to be made in a province if the ordinary location of the meter is in the province when the recipient of the supply pays an amount to the Corporation for the purpose of paying that postage.

47. The ordinary location of the meter at a particular time is deemed to be the location that the supplier and the recipient mutually agree is the ordinary location of the meter at that time and this location may change from time to time.

48. Where the supply is made under a bill of lading, the supply is subject to the general place of supply rule for freight transportation services, which is based on the destination of the service.

Permit imprint

49. If the payment of postage for a mail delivery service that is supplied by the Canada Post Corporation, otherwise than under a bill of lading, is evidenced by a permit imprint, section 4 of Part VII of Schedule IX deems the supply of the service to be made in the province in which the recipient of the supply deposits the mail with the Corporation in accordance with the agreement between the recipient and the Corporation authorizing the use of the permit imprint.

50. Where the supply is made under a bill of lading, the general place of supply rule for freight transportation services applies, which is based on the destination of the service.

First Nations goods and services tax – place of supply

51. The FNGST is a tax that may be imposed by a band council, other governing body of a First Nation or an Indigenous government on the lands that it governs. The FNGST at the rate of 5% applies to most supplies of property and services made on these lands.

52. Everyone has to pay the FNGST on the supply of property and services made on lands where the FNGST applies including Indians, Indian bands, or band-empowered entities. However, certain provincial and territorial governments do not pay the FNGST. The CRA uses the term Indian in this memorandum because it has legal meaning under the Indian Act.

53. For more information on the FNGST and the First Nations and Indigenous governments that impose the FNGST, go to First Nations Goods and Services Tax. You may also refer to Technical Information Bulletin B-102, First Nations Goods and Services Tax - Place of Supply.

Supply is deemed to be made on FNGST lands in a non-participating province

54. The FNGST replaces the GST where the provincial place of supply rules deem the supply to be made on the lands where an FNGST is imposed and where those lands are located in a non-participating province. The supply is subject to the FNGST at the rate of 5%.

Supply is deemed to be made on FNGST lands in a participating province

55. The FNGST replaces the federal part of the HST where the provincial place of supply rules deem the supply to be made on the lands where an FNGST is imposed and where those lands are located in a participating province. The supply is subject to the FNGST at the rate of 5%.

56. Provided the purchaser meets the criteria set out in GST/HST Technical Information Bulletin B-039, GST/HST Administrative Policy – Application of the GST/HST to Indians, the provincial part of the HST would be relieved. Where the purchaser does not qualify for relief of the provincial part of the HST under Technical Information Bulletin B-039, registered vendors are required to collect the provincial part of the HST in participating provinces unless relief of that part is provided by some other legislation or policy.

Supply is deemed to be made in Canada, but not on FNGST lands

57. Where the provincial place of supply rules deem the supply to not have been made on FNGST lands, and the supply is made in Canada, then either the GST or the HST will apply depending on whether or not the supply is deemed to be made in a participating province.

Further infomation

All GST/HST technical publications are available at GST/HST technical information.

To make a GST/HST enquiry by telephone:

  • for GST/HST general enquiries, call Business Enquiries at 1‑800‑959‑5525
  • for GST/HST technical enquiries, call GST/HST Rulings at 1‑800‑959‑8287

If you are located in Quebec, call Revenu Québec at 1‑800‑567‑4692 or visit their website at revenuquebec.ca.

If you are a selected listed financial institution (whether or not you are located in Quebec) and require information on the GST/HST or the QST, go to GST/HST and QST information for financial institutions, including selected listed financial institutions or:

  • for general GST/HST or QST enquiries, call Business Enquiries at 1‑800‑959‑5525
  • for technical GST/HST or QST enquiries, call GST/HST Rulings SLFI at 1‑855‑666‑5166

Page details

2026-04-09