No GST will be exigible on a supply (including a taxable supply) of intellectual property made by a resident or non-resident of Canada to a non-resident of Canada where the supply is made outside Canada. A supply of intellectual property will be considered to be made outside Canada if the intellectual property may not be used in Canada, or the intellectual property relates to real property situated outside Canada, to tangible personal property ordinarily situated outside Canada or to a service to be performed wholly outside Canada, and also will be deemed to be made outside Canada if the supplier is not registered and does not make the supply in the course of a business carried on in Canada.
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