197.3. A supply of a financial service (other than a supply described in section 197.4) made by a financial institution to a person not resident in Canada is a zero-rated supply, unless the service relates to(1) a debt that arises from(a) the deposit of funds in Canada, if the instrument issued as evidence of the deposit is a negotiable instrument, or
(b) the lending of money that is primarily for use in Canada;
(2) a debt for all or part of the consideration for a supply of an immovable that is situated in Canada;
(3) a debt for all or part of the consideration for a supply of a movable property that is for use primarily in Canada;
(4) a debt for all or part of the consideration for a supply of a service that is to be performed primarily in Canada; or
(5) a financial instrument (other than an insurance policy or a precious metal) acquired, otherwise than directly from an issuer not resident in Canada, by the financial institution acting as a mandatary.