Requesting a GST/HST Ruling or Interpretation

GST/HST Memorandum 1-4
March 2026

This version replaces the one dated May 2021. This memorandum has been revised to update the contact information and to remove the information related to excise duty, excise tax, the air travellers security charge, the tax on insurance premiums, and the fuel charge. For information on these duties, taxes, and charges, go to Requesting an excise and specialty tax ruling or interpretation.

Table of Contents

• General
  • Technical publications
  • General and technical enquiries
• Rulings
• Interpretations
• Information to include with a request for a ruling or interpretation
• How to submit a ruling or interpretation request
• Processing requests for rulings and interpretations
• Providing a ruling or interpretation
• Reconsideration of a ruling or interpretation
• Limitations of rulings
• Rulings and audit
• When rulings are revoked or amended
• Circumstances where a ruling may not be issued
• Third-party authorization
• Service standards

General

1. We, the Canada Revenue Agency (CRA), offer a variety of technical information services, free of charge, to assist you in understanding your obligations and in complying with the law. We provide information about:

• the GST/HST under Part IX of the Excise Tax Act (ETA)
• First Nations taxes under the Budget Implementation Act, 2000, the First Nations Goods and Services Tax Act, and other legislation relating to agreements with First Nations and Indigenous governments
• the Quebec sales tax (QST) under the Act respecting the Québec sales tax and the relevant provisions of the Tax Administration Act with respect to persons that are selected listed financial institutions (SLFIs) for GST/HST or QST purposes or both

Technical publications

2. If you have a question about how particular legislation applies to your operations, you may consult our broad range of technical publications, including the following:

• GST/HST memoranda series and the GST memoranda (published from 1990 to 1994) discuss in detail how the provisions in Part IX of the ETA and its related schedules apply
• GST/HST Technical Information Bulletins provide detailed information on programs, administrative policies, and changes to the GST/HST legislation
• GST/HST Policy Statements set out the CRA's interpretation of specific GST/HST issues or legislative provisions
• GST/HST Notices discuss various matters, such as details about new and existing programs or policy positions, and how we administer the particular legislation, or any changes related to the administration of the law
• GST/HST Info Sheets are written in plain language and provide clear and concise explanations of specific GST/HST issues
• The Excise and GST/HST News highlights recent developments in the administration of the GST/HST, the QST for persons that are SLFIs for GST/HST or QST purposes or both, the underused housing tax, and First Nations taxes, as well as the air travellers security charge, excise duties, excise taxes, the fuel charge, the luxury tax, and the tax on insurance premiums

3. All technical publications and additional information, including forms and prescribed rates, are available at:

• GST/HST technical information
• GST/HST and First Nations peoples

4. To be notified of new or revised technical publications through our electronic subscription service, go to Canada Revenue Agency electronic mailing lists.

General and technical enquiries

5. For general enquiries regarding the GST/HST, the QST for a person that is an SLFI for GST/HST or QST purposes or both, and First Nations taxes, call 1‑800‑959‑5525.

6. We also provide a service of answering technical enquiries. For technical enquiries regarding:

• the GST/HST or one of the First Nations taxes, call 1‑800‑959‑8287
• the GST/HST or the QST for a person that is an SLFI for GST/HST or QST purposes or both, call 1‑855‑666‑5166

7. For GST/HST digital economy enquiries:

• if you are calling from within Canada or the United States, call 1‑833‑585‑1463
• if you are calling from outside Canada and the United States, call 613‑221‑3154 (collect calls accepted)

8. While a ruling cannot be provided over the telephone, we can provide general interpretations of legislation or other assistance. After receiving a telephone enquiry, we aim to provide a response within one working day.

9. In the course of answering a technical enquiry, we may request documentation. Where you require certainty on how the legislation applies to your operations or transactions, we will advise you to request a written ruling or interpretation.

Rulings

10. A ruling is a written statement that sets out our position on how the relevant provisions of the legislation apply to a clearly defined fact situation. Usually, a ruling relates to ongoing issues or transactions and does not specify a time limit. A ruling may also be given in advance of any proposed transaction and may be restricted to specific persons, transactions, or time periods.

11. We will issue a ruling once you provide all the relevant facts of an issue, transaction, or series of transactions, and all supporting documents. For more information, refer to the Information to include with a request for a ruling or interpretation section of this memorandum.

12. We will not issue a ruling where the request relates to a hypothetical situation or where you do not provide sufficient facts. In such cases, we may instead provide an interpretation of the relevant provisions of the legislation to help you fulfill your obligations under the law.

13. We consider ourselves to be bound by the rulings that we issue, subject to the limitations outlined in this memorandum.

Interpretations

14. An interpretation is a written statement that sets out our view of how legislation applies to a generic fact situation. An interpretation sets out our understanding of certain provisions of a specific act or regulation. An interpretation may also be provided in respect of legislative provisions that have not yet become law. We are not bound by the interpretations that we issue.

15. When you request an interpretation, you should provide sufficient information to enable us to understand the issues to be considered. For more information, refer to the Information to include with a request for a ruling or interpretation section of this memorandum.

Information to include with a request for a ruling or interpretation

16. Along with your request for a ruling or interpretation, you must provide all relevant documentation. Complete documentation helps us answer requests in a timely manner and ensure that, in the case of a ruling, the answer provided addresses your specific situation. If you do not supply complete documentation with your request, this may impact our ability to provide a ruling or interpretation.

17. Your request for a ruling or interpretation should include the following:

• your name, telephone number, and mailing address
• your business number (BN) or other applicable CRA tax identifier
• where a representative (for example, an accountant, bookkeeper, lawyer) is acting on your behalf, written third-party authorization certifying that the representative is authorized to act on your behalf and outlining the purpose, scope, and period of the authorization (for more information on third-party authorization including a sample, refer to the Third-party authorization section of this memorandum)
• written third-party authorization is also required for representatives requesting a ruling or interpretation which applies to a particular named person that is a client of the representative
• a statement indicating whether the request involves any of the following:
  • a matter for which we are already considering a ruling or interpretation request
  • a matter currently under audit
  • a matter for which you have filed a notice of objection
  • a matter before the courts
• a complete description of the facts of each issue or transaction
• for each transaction covered by the request:
  • a statement of its purpose
  • your interpretation of the application of the relevant legislative provisions
  • your interpretation of common law or Civil Code of Québec issues relevant to the request (for example, the existence of a trust or agency relationship)
  • a description of the specific interpretative concern upon which the request is based
• a description of significant events or transactions forming a series of events or transactions that includes the events or transactions in respect of which the ruling is requested
• copies of any relevant supporting agreements or documents, together with references to, and summaries of, the specific provisions of these agreements or documents that relate to the request
• where the request is for a ruling that concerns the application of anti-avoidance rules, include a submission to establish that the transaction will not result, directly or indirectly, in a misuse or abuse of the provisions of the relevant act
• an analysis, where applicable, of authorities known to you or your representative that support your position and those that do not (for example, Canadian case law citations, published commentaries, references to jurisprudence), with comments as to why the authorities in support of your position should prevail

18. When a request goes beyond a narrow set of transactions, you should provide all information related to your situation, describing it in as much detail as possible and providing as many facts as possible.

19. In addition to the information identified in paragraphs 17 and 18 of this memorandum, a request for a ruling or interpretation concerning supplies of grocery products should contain the information outlined in GST/HST Notice 338, Information Requirements for Basic Grocery Ruling Requests.

20. Information that you provide in the course of a request for a ruling or interpretation is protected under the confidentiality provisions of the acts that we administer, as well as under the Access to Information Act and the Privacy Act. We do not release this confidential information to the public. However, certain rulings and interpretations that we issue are made available to the public in severed form. Under this process, confidential information (that is, information that reveals the identity of the person to whom it relates) contained in the ruling or interpretation is removed.

21. Any information provided to the GST/HST Rulings Directorate in respect of ruling and interpretation requests may be shared with other persons such as other branches of the CRA and other federal, provincial, or territorial government institutions for the administration of the acts we administer and within the limits of the confidentiality-of-taxpayer-information and to the extent authorized by section 295 of the ETA. Personal information collected for the purpose of processing requests for rulings and interpretations may be used by the CRA for any other purpose related to the administration and enforcement of the ETA such as compliance and appeals.

22. Under the Privacy Act, individuals have a right of protection, access to, and correction or notation of their personal information and the right to file a complaint with the Privacy Commissioner of Canada regarding our handling of their information.

How to submit a ruling or interpretation request

23. A request for a ruling or interpretation concerning the application of the GST/HST, the QST for a person that is an SLFI for GST/HST or QST purposes or both, or First Nations taxes can be submitted electronically. Sign in to your CRA account to submit a request using the "Submit documents" service. To register for your CRA account, refer to Register for a CRA account. This service is available to individuals, businesses, and authorized representatives that have registered to use this service.

24. A request, along with all relevant supporting documents, can also be sent by mail or fax to:

GST/HST Rulings Directorate
Canada Revenue Agency
Place de Ville Tower A 5th floor
320 Queen St
Ottawa ON  K1A 0L5
Fax: 418‑556‑1846

25. The CRA does not provide assurance with respect to the protection, confidentiality, or security of facsimile transmissions. Please note that because CRA security policies now prohibit sending documentation containing protected information to taxpayers by fax, the GST/HST Rulings Directorate will not send any communication by fax.

Processing requests for rulings and interpretations

26. Upon receipt of your request for a ruling or interpretation, we will send you an acknowledgement letter that includes a unique ruling or interpretation case number and information on how to contact us about your request. When work on your file begins, an officer will contact you to clarify facts and may request additional information or correct any misunderstanding of the information provided.

27. Our policy is to review requests in the order in which they are received. However, a ruling or interpretation may be delayed if it involves the review of an issue upon which we have not yet adopted a position, or if we are currently in the process of reconsidering our existing position. A ruling or interpretation may also be delayed if further information or documentation is required. If a ruling is required by a certain date (for example, before the closing date of a contract), you must submit the request with sufficient lead time. For more information on our service standards, refer to the Service standards section of this memorandum.

28. If your request includes multiple items or issues, we may respond with separate ruling or interpretation letters.

Providing a ruling or interpretation

29. We will send the ruling or interpretation letter to you unless you have completed a third-party authorization letter. In that case, we will send the ruling or interpretation letter to your authorized representative.

Reconsideration of a ruling or interpretation

30. If you disagree with a ruling or interpretation, there is no formal appeal process. However, we may reconsider a ruling or interpretation if requested to do so.

31. You may submit a written request for reconsideration to the GST/HST Rulings Directorate using the contact information found under the How to submit a ruling or interpretation request section of this memorandum. The request should include the ruling or interpretation case number, the reasons for your concerns, and the information outlined in paragraph 17 of this memorandum. If a representative is acting on your behalf, you must also submit a third-party authorization.

32. Upon receipt of a written request for reconsideration, we will send you or your representative an acknowledgement letter that provides a case number and information on how to contact us about the request submitted. We will subsequently contact you or your representative to discuss the nature of the concerns.

33. Once the review is complete, we will inform you or your representative of the outcome in writing.

Limitations of rulings

34. The validity and application of a ruling is limited by the completeness and accuracy of the information upon which it is based.

35. A particular ruling applies only to the person that requests it (the requestor) or to the person on whose behalf it is requested, and applies only to the fact pattern and issues covered by the ruling.

36. A ruling may specify other qualifications as appropriate (for example, the time limit within which the ruling will apply).

37. We do not issue rulings involving proposed or draft legislation, draft regulations, federal budget proposals, or Notices of Ways and Means motions. In these situations, we may choose to issue an interpretation.

38. We are not bound by a ruling where the validity of the ruling is affected by a subsequent change to the law, our interpretation of the law, or our administrative policies. We cease to be bound as of the effective date of any such change. We inform the public of such changes by issuing notices, the Excise and GST/HST News, policy statements, and other GST/HST publications on our website and providing links to the Department of Finance press releases; as well as by liaising with industry associations; and, where feasible, by contacting registrants. A person should ensure that they keep current with any legislative, interpretative, or administrative change that might affect their obligations under the law.

Rulings and audit

39. In the event of a CRA audit, the information and transaction details upon which we have based the ruling are subject to review. For example, a review may determine whether all material facts were accurately stated in the ruling request and whether the transaction or series of transactions were carried out as described.

40. When we receive a request for a ruling on an issue that is under audit, we will communicate with the CRA auditor to discuss the request.

When rulings are revoked or amended

41. When we discover that a ruling is incorrect, we may opt to revoke or amend the ruling.

42. When a ruling is incorrect because of an error on our part, the revocation or amendment generally applies as of the date of the revocation or amendment letter. However, there may be circumstances where we would consider a request to have the revocation or amendment take effect on the date of the original ruling or on another appropriate date.

43. When a ruling is incorrect because you did not provide complete or accurate information, the revocation or amendment applies from the date the original ruling was issued.

Circumstances where a ruling may not be issued

44. We will not issue a ruling when we consider that it would be inappropriate to do so. The following are some examples of when a ruling may not be issued:

• The request concerns an issue or transaction that is the same in character as a matter for which you have already requested a ruling
• The request concerns an issue or transaction that is the same in character as a matter that you have in dispute, or under assessment or proposed assessment, with the CRA
• The request concerns a matter in respect of which a notice of objection filed by you is being considered
• The central issue involves a matter that is before the courts or, if a judgement has been issued, where an appeal to a higher court is being considered
• The request contains alternative courses of action on your part
• The request is for a determination of the fair market value of property
• The request concerns tax-related calculations (for example, the amount of net tax payable for GST/HST purposes)
• The request is for a determination of fact and the circumstances are such that all the pertinent facts cannot be established (this could include issues involving the carrying on of a business; the existence of a partnership, a trust, or an agency relationship; or the reasonableness of a cost allocation method)
• The request involves proposed or draft legislation, draft regulations, budget proposals, or Notices of Ways and Means motions
• The ruling would require an opinion on generally accepted accounting principles or commercial practices
• The request is for an interpretation of a law that we do not administer (for example, foreign laws, provincial laws, and laws administered by other federal departments)
• We have reason to believe that the request may be in respect of illegal activities

45. When we decide not to issue a ruling, we will inform you or your representative in writing of our reasons.

Third-party authorization

46. A third-party authorization letter is required where a third party is acting on your behalf. The authorization should be specific to the request for a ruling or interpretation.

47. Provide the name, address, and telephone number of the third party. If the third party is an individual in a firm, provide both the name of the individual and that of the firm.

48. Specify the tax to which the authorization applies (for example, the GST/HST, the QST for persons that are SLFIs for GST/HST or QST purposes or both, First Nations taxes).

49. Indicate if the authorization applies for one or more specific periods of time (for example, one or more GST/HST reporting periods, a calendar year, a fiscal year).

50. Send the authorization letter to the GST/HST Rulings Directorate using the contact information found under How to submit a ruling or interpretation request section of this memorandum.

51. If you wish to revoke a third-party authorization, you must inform us in writing. A request for revocation should contain all the information that was provided with the initial request for authorization.

52. Other types of CRA authorization forms (for example, Form AUT-01, Authorize a Representative for Offline Access) are not acceptable for the purposes of a ruling or interpretation request.

Service standards

53. We have published Service Standards in the CRA for responding to telephone enquiries on technical GST/HST issues and written requests for GST/HST rulings and interpretations.

54. For telephone enquiries, our goal is to respond within two minutes of a caller choosing to speak with an agent. We aim to achieve this service standard 80% of the time.

55. For written requests for GST/HST rulings and interpretations, our goal is to respond within 45 business days of our receipt of the request and all relevant facts and supporting documentation. This excludes highly technical and precedent-setting or policy-setting rulings and interpretations. By receiving as much information as possible with the initial request, we can provide a response that is more accurate, timely, and complete. We aim to achieve this service standard 80% of the time.

Further information