# EXM-N04 — Sponsorship. ETA s.135

**Flag: Current** — Verified against the live source. Safe to cite.

**Sponsorship.** ETA s.135: where a public sector body supplies a service, or licenses its copyright, trade-mark, trade-name or similar IP, to a sponsor for use exclusively in publicizing the sponsor's business, it is deemed not to be a supply. Exception: where the payment is primarily (more than 50%) for advertising on television or radio, or in a periodical publication, it is a taxable advertising service. Real property and naming rights are **not** relieved — CRA's example: a $1M naming-rights deal is taxable

## Sources

- RC4081 (primary): https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/rc4081/gst-hst-information-non-profit-organizations.html

Jurisdiction: FED · Verified 2026-08-27 · Review: legislative