http://decision.tcc-cci.gc.ca/site/tcc-cci/decisions/en/item/62998/index.do 
Three-W Canada International Corporation v. The Queen[1] (September 16, 2013) dealt with a taxpayer that recruits student for private schools in Canada and the United States:
[2] Three-W carries on the business of recruiting foreign students abroad for private schools in Canada and the United States. It has been assessed for not having collected and remitted GST or HST on the services it provided to Canadian schools.
[3] Three-W maintains an office in Jason Wang’s London, Ontario home. This serves as its registered office and is used by Jason Wang to attend to Three-W’s business when he is not out of the country. Three-W does not meet with school representatives or students at this office. E-mail correspondence is sent from the London, Ontario office to Canadian schools and to Three-W’s Chinese business partners and agents by Mr. Jason Wang.
4] Jason Wang finds and maintains client schools in Canada and the United States. He meets in person with the Canadian schools’ representatives at their campuses. He signs written agreements on behalf of Three-W with the Canadian schools while he is in Canada. He and Tony also meet with students at their Canadian schools at times, for example when there are cultural adjustment issues, behaviour issues, plagiarism issues and school related, host family placement, or visa renewal issues. The Canadian schools spoke directly with Mr. Jason Wang regarding student problems.
The sole issue was whether it provided services in Canada that were subject to GST. The court rejected the taxpayer’s arguments that all of its services were rendered outside of Canada:
[11] While the taxpayer may take the position that much or even most of its revenue-generating activities takes place in China, the evidence is clear that its student recruitment services were carried on in part in Canada. This is the case even after allowing for the fact that, although issuing bills and receiving payment may be an integral part of carrying on business in Canada, it does not necessarily constitute part of the activities of performing the service sold to the Canadian schools being that of student recruitment. Meeting with the students in Canada, and meeting with schools in Canada as part of an ongoing student recruitment contract to be renewed, with commissions payable for each term the student continues to be enrolled, is actually a very important part of performing the service since it is the Canadian schools that are Three-W’s paying customers and no commission is paid if students do not return the following semester for any reason whatever. The appeal must therefore be dismissed. Three-W is in a services business which services include the Canadian activities of servicing the schools and students in Canada.
[12] I can not accept the taxpayer’s submission that the only service which Three-W was paid to provide was that of recruiting students and it was entitled to its commissions once the students were registered regardless. It is one of the taxpayer’s positions that, when it later attended to its school customers and its placed students in Canada, it was providing a separate service of keeping customers satisfied and happy. Respondent’s counsel referred to this as “after-service service” playing on the term after-sales service. The oft-quoted decision of this Court in
O.A. Brown LTD. v. Canada, [1995] T.C.J. No. 678 deals with the issue of when there is a single supply involving multiple services and when there are separate supplies (in paragraphs 21 and 29.)[1] The post-initial enrolment services provided by Three-W in Canada to the schools and the students is an integral part of the overall supply of its student recruitment services for a single fee. They can not be regarded as separate supplies when they are an integral component of the overall supply.
This seems a practical, common sense decision soundly based on the facts before the court.
[1] 2013 TCC 295.