Remissions for Service Fees

The Canada Revenue Agency (CRA) offers services for Advance income tax rulings and Taxation statistical analyses and data processing on a fee-for-service basis, which are subject to the Service Fees Act.

In accordance with the Act, each of these fees is subject to achievement of stated service standards for which remissions, or partial refunds, are to be made to clients in instances where the service standards are not fully achieved.

The service standards and related policies and procedures for issuing these remissions are as follows:

Advance Income Tax Ruling Fees

Service standards

Our objective is to issue an advance income tax ruling (Ruling) to the client within a specified, agreed-upon time period. The service standard is 90 business days commencing with the receipt of all information required from the client as outlined in Information Circular IC 70-6, Advance Income Tax Rulings and Technical Interpretations.

Our objective is to complete a pre-ruling consultation teleconference with the client within a specified, agreed-upon time period. The service standard is within 15 business days from the date the CRA confirms to the client that the Pre-ruling Consultation request has been accepted as outlined in Information Circular IC70-6.

In some cases, achieving the 90 or 15 business days service target may not be possible due to delays outside of the CRA’s control. This may arise in situations involving exceptionally complex cases, requests to expand and change the scope of the Ruling or pre-ruling consultation, or cases that require intra-governmental consultation, for example with the Departments of Justice or Finance. In those circumstances, when the service target date needs to be adjusted, the CRA will inform the client in advance and establish an alternate mutually agreed upon service target date.

Remissions

For purposes of this discussion:

Remission of the service fee will be granted when the completion date is subsequent to the service target date. Remissions, if applicable, will be processed as a reduction to the client invoice.

Remissions will be calculated on an incremental basis as a percentage discount on the rate applicable to the hours worked in each period subsequent to the service target date, as follows:

For Rulings:
Number of business days past the service target date Percentage reduction of the hourly fee for work in the period
1 to 30 days 12.5%
31 to 60 days 25%
61 to 90 days 37.5%
91+ days 50%
For pre-ruling consultations:
Number of business days past the service target date Percentage reduction of the hourly fee for work in the period
1 to 5 days 12.5%
6 to 10 days 25%
11 to 15 days 37.5%
16+ days 50%

Interest is not paid for remissions made under section 7 of the Service Fees Act.

Taxation statistical analyses and data processing services fees

Service standard

Due to the complexity and the availability of the data, some requests may take more or less time to complete and deliver. The CRA’s service standard is to issue requested statistical information on or before a mutually agreed-upon service target date with a performance target of providing this information on or before this date 90% of the time.

After receiving all the information required for the request, the CRA and client will agree on a mutually acceptable date to deliver the requested information (referred to as the “service target date” below).

Completion date for the purposes of this directive will be the date that the requested information is delivered to the client by the CRA.

Remissions

Remissions will be granted where the completion date exceeds the service target date, as follows:

Service target date + 1-15 calendar days = 25% reduction in total charges
Service target date + 16+ calendar days = 50% reduction in total charges

Remissions, if applicable, will be processed as a reduction to the client invoice.

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