Do I Charge GST/HST to US Clients? Usually No — Zero-Rating for Exports, the Proof You Need, and the Traps Inside 'Usually'

The instinct is right and incomplete: exports leave Canada free of GST/HST, but the mechanism is zero-rating specific supplies under specific conditions — not a blanket exemption for anyone invoicing in US dollars. The architecture first: a GST/HST registrant charges tax based on place-of-supply and zero-rating rules; a zero-rated supply is taxable at 0% — which matters because the registrant keeps full input tax credits on the costs behind it (the feature that makes exporting GST-clean rather than GST-trapped), while genuinely exempt supplies would strand those credits. Goods: tangible goods delivered or made available outside Canada, or shipped for export under the export conditions, zero-rate cleanly — the courier waybills, export documents, and shipping records being the substantiation the CRA asks for when it asks. Services: the general zero-rating rule covers services made to a non-resident — with a list of carve-outs that supply the traps: services rendered to an individual while that individual is in Canada; services in respect of real property situated in Canada (the US developer's Canadian-project consulting is taxable however American the client); services in respect of tangible personal property situated in Canada; advisory and professional services generally zero-rate to non-residents, which is why the consultant, developer, and designer serving US clients from Canada mostly lives at 0% — but the non-resident status of the client is a fact to verify and paper (a certificate or reasonable evidence of non-residence and, where relevant, non-registration), because invoicing a US company's Canadian branch or a client who is factually resident flips the answer. Intangibles and digital products follow their own place-of-supply logic. Registration itself is unaffected by the zero-rating: a Canadian business over the small-supplier threshold registers regardless of how export-heavy its sales are — and wants to, for the input credits — while the export-only business's returns simply show zero-rated revenue and refundable credits, the pattern that also invites the CRA's export-verification letters the substantiation file exists to answer. The mirror-image questions — must the US customer self-assess anything, does US sales tax apply to what you sold them — belong to the US-side nexus analysis, and the one-sentence version is that your GST/HST answer says nothing about your US sales tax answer: the Canadian SaaS company zero-rating its GST can simultaneously owe registration in nine US states, which is why the two analyses run as siblings, never substitutes.

Key takeaways

• Zero-rated ≠ exempt, and the difference is your input credits: 0% on the sale, full ITCs on the inputs — the export-heavy registrant is typically in net refund position, legitimately, forever.
• Goods: delivered outside Canada or exported under the conditions → zero-rated, with the shipping paper trail kept. Goods delivered to the customer in Canada (their Canadian site, their Canadian carrier pickup) → taxable, whoever pays the invoice.
• Services: made to a non-resident → generally zero-rated, subject to the carve-outs — in-Canada individuals, Canadian real property, Canadian-situated goods, and a handful of others. The client's non-residence is verified and papered, not assumed from the address on the invoice.
• The recurring traps: the US client's Canadian branch or Canadian-registered affiliate as the true recipient; the Canadian-real-property engagement for an American owner; the training delivered to the US client's staff while they sit in your Toronto office; and the intercompany services to your own US subsidiary — related-party status doesn't change the rules but guarantees the scrutiny.
• Registration and returns: over the small-supplier threshold, register regardless of export mix; charge 0% correctly rather than not charging; and keep the export/non-residence substantiation file the refund-position returns will eventually be asked to support.
• Your US-side obligations are a separate analysis: zero-rating Canadian GST/HST coexists with US state sales tax nexus and the income-tax PE question — run the sibling analyses together at the same annual review.

The invoice-level decision path

Per client, once, and per engagement where facts differ: (1) what is supplied — goods, services, intangibles, or the mixed bundle that needs unbundling; (2) who is the recipient in substance — the non-resident parent or the Canadian affiliate actually receiving the benefit; (3) where — delivery point for goods, the carve-out screens for services (anyone in Canada? any Canadian real or tangible property in respect of which?); (4) evidence — the non-residence certificate or file, the export documents; (5) the invoice coded accordingly, with 0% shown as zero-rated rather than tax simply absent. Systematized once in the billing system, the analysis runs itself — and the annual review re-screens the client list for the branch that opened, the project that touched Canadian property, and the engagement letter whose recipient quietly changed.

Worked example

A Waterloo software consultancy bills three US-headquartered clients. Client one: SaaS implementation for a Chicago manufacturer, all work remote, recipient verified non-resident and unregistered — zero-rated across the engagement; the file holds the client's non-residence confirmation and the contracts; the firm's GST/HST returns show the revenue at 0% with full ITCs on its Waterloo costs, a steady small refund position. Client two: the same manufacturer's Mississauga plant signs its own statement of work for on-site systems training — recipient is the Canadian-registered entity and the service touches Canada on multiple grounds: HST charged at Ontario's rate on that engagement, correctly, alongside the zero-rated parent work. Client three: a Phoenix real estate fund engages them to model a Vancouver acquisition — service in respect of Canadian real property: taxable despite the pure-US client, GST/HST charged, the carve-out the firm's billing checklist flags automatically since the year it missed one. Meanwhile the sibling analysis runs on schedule: the firm's US revenue crosses two states' sales-tax thresholds this year — registrations filed — and its zero-rated Canadian returns and its Arizona sales tax collection coexist without contradiction, because they never were the same question.

Official sources

"Some supplies are zero-rated under the GST/HST – that is, the GST/HST applies at a rate of 0%. This means that you do not charge GST/HST on these supplies, but you may be eligible to claim ITCs for the GST/HST paid or payable on property and services acquired to provide these supplies." Exports of goods and services are zero-rated. — Canada Revenue Agency, RC4022 General Information for GST/HST Registrants, https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/rc4022/general-information-gst-hst-registrants.html

"The business profits of a resident of a Contracting State shall be taxable only in that State unless the resident carries on business in the other Contracting State through a permanent establishment situated therein." — Canada-United States Tax Convention, Article VII, https://www.canada.ca/en/department-finance/programs/tax-policy/tax-treaties/country/united-states-america-convention-consolidated-1980-1983-1984-1995-1997.html

Practitioner note

The GST/HST export answer is friendlier than clients expect and more conditional than they invoice: zero-rating pays you back your input tax while the carve-outs — Canadian property, Canadian branches, anyone physically here — convert individual engagements without warning. Our setup is a billing-system decision path plus a substantiation file, and the annual habit is re-screening the client list, because the taxable engagement inside the zero-rated relationship is the finding in every GST export review we've ever seen.

See also: For a US business selling into Canada and GST/HST, see a US business selling into Canada and GST/HST; and browse every cross-border tax topic guide, organized by situation.

Next step

Fairlight prepares the GST/HST export program — supply-by-supply zero-rating analysis, non-residence and export substantiation files, billing-system coding, and the paired US nexus review each year. See cross-border pricing or book a call.