T2 Corporation – Income Tax Guide – Before you start

From: Canada Revenue Agency

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References in this guide

All legislative references are to the Income Tax Act and Income Tax Regulations of Canada, unless stated otherwise. This guide does not replace the Income Tax Act or its regulations.

We also refer to information circulars (ICs) and interpretation bulletins (ITs) that we publish to give you more technical information. A new series of technical publications, called the income tax folios, is progressively replacing the IT bulletins. This process is taking place over several years. To be notified of new or updated income tax folios, subscribe to our Electronic mailing list – Income Tax Technical Publications.

Many of our publications, including forms, schedules, ICs, ITs, and folios are available at Forms and publications. A table at the end of this guide lists forms by number.

AgriStability and AgriInvest programs

The CRA is not involved in administering the AgriStability and AgriInvest programs for corporations. For more information on these programs, go to AgriStability and AgriInvest.

Our service pledge

The CRA will process 90% of T2 corporation income tax returns within 45 days for the electronic version and 90 days for the paper version.

Who has to file a T2 return?

Resident corporations

All corporations — including non-profit organizations, tax-exempt corporations, and inactive corporations — have to file a T2 return for every tax year, even if there is no tax payable. The only exceptions to this rule are tax-exempt Crown corporations, Hutterite colonies, and corporations that were registered charities throughout the year.

Non-resident corporations

A non-resident corporation has to file a T2 return if, at any time in the year, one of the following situations applies:

  • it carried on business in Canada
  • it had a taxable capital gain
  • it disposed of taxable Canadian property, unless the disposition meets all the criteria listed below

This requirement applies even if the corporation claims that any profits or gains realized are exempt from Canadian income tax due to the provisions of a tax treaty.

Business is defined in subsection 248(1) and the extended meaning of carrying on business (in Canada) is defined in section 253.

The references to taxable capital gain do not include any gain resulting from the disposition of shares that are listed on a designated stock exchange (other than taxable Canadian property).

A non-resident corporation also has to file a T2 return in a number of situations, including:

Even if neither of these requirements applies, a non-resident corporation may still want to file a return if any of the following situations apply:

  • when it wants to claim a refund
  • when it wants to elect to pay Part I tax on the net amount of timber royalty income or rental income from real property under subsection 216(1) for the current year
  • when it wants to elect to pay Part I tax on the net amount of acting services under subsection 216.1(1) for the current year


Non-resident corporations must file their T2 return, schedules, and the General Index of Financial Information in Canadian funds only. They are not eligible to file in a functional currency per section 261.

If you have questions about non‑resident returns, go to Businesses – International and non-resident taxes.         

Dispositions of taxable Canadian property (certificates of compliance)

A non-resident corporation that disposes of taxable Canadian property must notify the CRA and may be required to get a certificate of compliance under section 116. For details, see Information Circular IC72-17, Procedures Concerning the Disposition of Taxable Canadian Property by Non-residents of Canada – Section 116.

A non-resident corporation that has a taxable capital gain or disposed of taxable Canadian property, including a corporation that may have received a certificate of compliance from the CRA, has to file a return, unless the disposition meets all the following criteria:

  • no tax is payable under Part I for the tax year
  • the corporation is not liable to pay any amount under the Act for any previous tax year (other than an amount covered by adequate security under section 116 or 220)
  • each taxable Canadian property disposed of in the tax year is either:
    • excluded property under section 116
    • property for which a certificate was issued under section 116

Taxable Canadian property excludes shares of corporations, and certain other interests, that, during the 60-month period ending at the time of determination, do not derive their value mainly from real or immovable property situated in Canada (including Canadian resource property and timber resource property).

Non-resident corporations claiming treaty exemption

If you carried on a treaty-protected business in Canada, had a taxable capital gain, or disposed of a taxable Canadian property that was treaty-protected property during the year (as defined in section 248), you have to complete all of the following lines on your return:

  • lines 001 to 082 of page 1
  • lines 164, 170, and 171 of page 2
  • lines 270 to 289 (except line 271) of page 3
  • lines 780 to 990, if applicable, of page 8

For each of the questions asked at lines 164, 170, and 171 on page 2 of the return to which your response is yes, complete the appropriate form or schedule and attach it to your return. In addition, you have to complete Schedule 91, Information Concerning Claims for Treaty-Based Exemptions.

Rental income from Canada

Rental income from Canada is subject to a 25% withholding on the gross rental income under Part XIII, unless the rate is reduced by a reciprocal tax treaty. A non-resident corporation can elect to be taxed under Part I on its net rental income by filing a T2 return under subsection 216(1) within two years of the end of the tax year. If the non-resident corporation has filed Form NR6, Undertaking to File an Income Tax Return by a Non-Resident Receiving Rent from Real Property or Receiving a Timber Royalty, it must file a T2 return under subsection 216(4) within six months of the tax year end. For more information, see IT393R2 – Election Re: Tax on Rents and Timber Royalties Non-Residents.


If you file a T2 return under section 216, include only rental income. If you have any other income, file a second T2 return.

Services rendered in Canada (withholding amount)

A non-resident corporation is subject to a 15% withholding under Regulation 105 on any fee or other amount paid to it for services rendered in Canada (regardless of whether the services are provided by an employee of the corporation or are sub-contracted to another party). This withholding is held on account of any potential tax liability that the corporation may have to Canada. The corporation's tax liability is determined when its Canadian income tax return is assessed.

A corporation related to a non-resident actor is subject to a 23% withholding tax under Part XIII on all amounts it receives for the acting services of the actor in a film or video production in Canada. This withholding tax represents the final tax liability for these acting services. The corporation may elect NOT to be taxed under Part XIII at the 23% rate by filing a return of income under Part I for the year. A non-resident corporation that has received a reduction (filed Form T1288) of this withholding tax from the CRA still has to file a return.


Send your Canadian T2 return that you elected to file under section 216.1 to the tax services office that processed application Form T1288 and issued the reduction. Write “Actor's election” at the top of page 1 of the return.

Section 153

How do you file your return?

Using tax preparation software

If you are preparing your return using tax preparation software, you must use CRA certified software. We certify commercial software to ensure that it meets our specifications. You can then file your return electronically using either:

You can also print the T2 Bar Code Return and mail it to the CRA.


Do not send the T2 bar code by fax. We do not accept it.

If you file through an electronic transmitter, you have to authorize the transmitter by completing a T183 CORP, Information Return for Corporations Filing Electronically, for each tax year. Do not send this form to us, but keep it in case we ask for it later.

T2 Auto-fill

T2 Auto-fill is a secure service that lets corporations and authorized representatives download information from the CRA to their tax preparation software. Using this service will ensure that certain return and account balances will match CRA's data. For more information on what T2 Auto-fill delivers, go to About T2 Auto-fill.

This service is not mandatory for certified software products. Some include it and others do not. If you have questions on the availability of the service, contact the software product company.

Mandatory Internet filing

All corporations with annual gross revenue of more than $1 million have to file their T2 return electronically, except for insurance corporations, non resident corporations, corporations reporting in functional currency and corporations that are exempt from tax payable under section 149 of the Income Tax Act. Corporations are subject to a penalty for non-compliant returns. For more information see What happens if you do not comply with mandatory Internet filing.

Corporation Internet Filing

When using Corporation Internet Filing, you can now specify hours and minutes in the tax year-end field of the T2 return for certain situations. See Specify hours and minutes.

Most corporations, including non-resident corporations, insurance corporations, and corporations claiming a scientific research and experimental development (SR&ED) amount, can file their return electronically using the Internet.

You must use CRA-approved software that has been certified for Corporation Internet Filing. By filing electronically, you will receive immediate confirmation that the CRA has received your return, enjoy faster processing and refunds, save on mailing costs, and help the environment by using less paper.

The T2 Attach-a-doc service allows corporations to attach supporting documentation such as certificates when they file their T2 return or within 24 hours of filing. This service is not mandatory for certified software products. Some include it and others do not. If you have questions on the availability of the service, contact the software product company.

If you are filing your T2 return electronically and you cannot use the T2 Attach-a-doc service to file your supporting documents with your return, send them to your tax centre (see Where do you file your paper return).

When sending paper documents, clearly identify your corporation's name, business number, and the applicable tax year-end on the documents.

If you are filing an election that does not have a prescribed form or prescribed manner, include it with the notes to your financial statements on the General Index of Financial Information (GIFI) to transmit the election electronically with your return, unless otherwise stated on a T2-related form.

For information on your eligibility, available software, and more, go to Corporation Internet Filing.

Filing without a web access code

You can file corporation returns online without a web access code using the “Transmit a return” service through:

2D bar code

CRA-certified software produces two-dimensional (2D) bar codes that contain the information needed to assess your return. We use bar code scanners to capture the information on our processing systems.

CRA-certified software produces a T2 Bar Code Return that contains the corporation's identification information, a summary of the financial data, bar codes, and a certification area.

The paper quality and print legibility of your T2 Bar Code Return have to meet our standards and must be printed on one side only. Use paper that is as durable as the 32M paper. The print quality has to be clear and dark enough to read and photocopy easily.

If the T2 Bar Code Return you file was not generated by software that we certified or does not meet our requirements, we will contact you to re-file the return, either in an approved format or using a copy of our forms available on our website.

Generally, in addition to the T2 Bar Code Return, certified software produces a client copy of the T2 return, which looks like a CRA T2 return available on our website. Keep the client copy for your files and send the T2 Bar Code Return to us. Do not send the T2 bar code by fax. We do not accept it.

North American Industry Classification System (NAICS) codes

All certified tax preparation software for T2 returns uses self-identified NAICS codes.

NAICS codes are hierarchical numerical codes designed to provide common definitions and descriptions of our industries and business activities. NAICS codes are up to six digits long. The Government of Canada as well as the governments of the provinces and territories use the data provided by NAICS codes for economic analysis and fiscal policy responses.

The integration of NAICS codes into T2 commercial tax preparation software packages means that corporations have to pick their main revenue generating business activity directly from a drop down list or a simple search. Active corporations that file their T2 returns either by Internet or on paper using 2D bar codes must choose the appropriate codes to describe their main revenue generating business activity.

Corporations using the return available on our website do not have to enter a NAICS code.

Avoid errors

It is important that you select the most accurate business activity the first time, since the first year's code is carried forward to following years, allowing for a simple validation of the description when there is no change in the main business activity.

If you do not select the business activity, problems and errors will result when you prepare the T2 return to be transmitted electronically or printed in bar-coded format.

If you have any questions on selecting NAICS codes to describe your corporation's main revenue generating business activity when filing your T2 return, call the Business Enquiries line at 1-800-959-5525.

Using the returns available on our website

We produce two different corporation returns.

T2 Corporation Income Tax Return

The T2 Corporation Income Tax Return has eight pages. Any corporation can use it.

T2 Short Return

The T2 Short Return is two pages plus a Schedule 1, Net Income (Loss) for Income Tax Purposes, a Schedule 8, Capital Cost Allowance (CCA), and a Schedule 50, Shareholder Information. It is a simpler version of the T2 Corporation Income Tax Return.

Two categories of corporations are eligible to use this return:

  1. You can use this return if the corporation is a Canadian-controlled private corporation (CCPC) throughout the tax year and this year, it has either a nil net income or a loss for income tax purposes.
  2. You can also use this return if the corporation is exempt from tax under section 149 (such as a non-profit organization).

In addition, the corporation must meet all of the following conditions to use this return:

  • it has a permanent establishment in only one province or territory
  • it is not claiming any refundable tax credits (other than a refund of instalments it paid)
  • it did not receive or pay out any taxable dividends
  • it is reporting in Canadian currency
  • it does not have an Ontario transitional tax debit
  • it does not have an amount calculated under section 34.2

If the corporation does not fit into either of the above categories or does not meet all of the above conditions, file a regular T2 return.

When do you have to file your return?

File your return within six months of the end of each tax year. The tax year of a corporation is its fiscal period.

When the corporation's tax year ends on the last day of a month, file the return by the last day of the sixth month after the end of the tax year.

When the last day of the tax year is not the last day of a month, file the return by the same day of the sixth month after the end of the tax year.

The CRA offers a mobile app that lets you create reminders of dates that are important for your business. For more information on the CRA Business Tax Reminders app, go to Mobile apps.


Table listing tax year-ends and filing deadlines
Tax year-end Filing deadline
March 31 September 30
June 30 December 31
August 31 February 28
September 23 March 23
October 2 April 2

When the T2 filing deadline falls on a Saturday, Sunday, or a public holiday recognized by the CRA, we will consider the return filed on time if it is sent on the first business day after the filing deadline.

You must file your return on time. If you do not, we can charge penalties on any return that was not sent by the filing due date. See What happens if you file your return late? for details.


You must file a return no later than three years after the end of a tax year to receive a tax refund.

Re-appropriation of T2 statute-barred credits

Under subsection 221.2(1), the minister of National Revenue may use discretion to re-appropriate T2 statute-barred credits to an established debt on an account associated with the same business number and administered by the CRA.

To request the re-appropriation of a T2 statute-barred credit, send us a completed Form RC431, Request for Re-appropriation of T2 Statute-barred Credits, with all the supporting documents. Complete a separate form for each unique business number.

You can also use the "Enquiries service" in My Business Account. You will have to provide the same details requested on Form RC431 in your enquiry. Keep the requested documents in case we ask for them later.

For more information, see the form or go to Re-appropriation of T2 statute-barred credits.

Where do you file your paper return?

The tax centres in Winnipeg, Sudbury, and Summerside process corporation tax returns. To find out where to mail your return, go to Where to send your corporation income tax (T2) return or call 1-800-959-5525.

Film and media tax credits

Film Services Units at the CRA provide services to corporations that may be entitled to receive the Canadian film or video production tax credit, the film or video production services tax credit, or other available provincial or media tax credits. For more information, including the location and contact number for the Film Services Unit serving your area, go to Film and Media Tax Credits.

When and how do corporations pay income tax?

Corporations have to pay income tax in monthly or quarterly instalments, unless the total of Part I, Part VI, Part VI.1, and Part XIII.1 taxes payable for either the previous year or the current year is $3,000 or less.

The balance of tax the corporation owes for a tax year is due within either two or three months of the end of that tax year, depending on the circumstances of the corporation.

Interest and penalties apply to late payments. To be on time, you have to make instalment payments and other payments on or before the due date by using one of the several methods of making online payments:

  • Pay online or by phone using a Canadian financial institution’s services
  • Pay online by using CRA’s My Payment service at My Payment
  • Pay by setting up a pre-authorized debit agreement using the My Business Account service
  • Pay by credit card through a third-party service provider

You can also pay in person at a Canadian financial institution or, for a fee, at a Canada Post retail outlet. To do so, you have to use a remittance form, which you can request online in My Business Account.


Remittance vouchers supplied after October 2018 have a Quick Response (QR) code printed on them that contains all the information you need so you can pay with cash or debit at a Canada Post retail outlet.

For more information, go to Make a payment or contact your financial institution.

We consider the payment to have been made on the day we receive it, and not on the day you send it.

Your payment due date may fall on a Saturday, Sunday, or a public holiday recognized by the CRA. If so, we will consider the payment as being received on time for calculating instalment interest and penalty if we receive the payment on the first business day after the due date.


Sometimes, penalties and interest on late payments can be cancelled or waived. For more information, see Cancel or waive penalties or interest.

Instalment due dates

Instalment payments for Parts I, VI, VI.1, and XIII.1 taxes are due on the last day of every complete month of a corporation's tax year. The first payment is due one month minus a day from the starting date of the corporation's tax year. The rest of the payments are due on the same day of each month that follows.

Eligible small-CCPCs can make quarterly instalment payments, instead of monthly ones. For more information, see Guide T7B-Corp, Corporation Instalment Guide.

You can view your instalment due dates by using the "Calculate Instalment payments" service through:

Balance-due day

Generally, all corporation taxes (with the exception of Part III and Part XII.6) are due two months after the end of the tax year. However, the tax is due three months after the end of the tax year if the following conditions apply:

  • the corporation is a CCPC throughout the tax year
  • the corporation is claiming the small business deduction for the tax year, or was allowed the small business deduction in the previous tax year and either
  • the corporation's taxable income for the previous tax year does not exceed its business limit for that tax year (if the corporation is not associated with any other corporation during the tax year) or
  • the total of the taxable incomes of all the associated corporations for their last tax year ending in the previous calendar year does not exceed the total of their business limits for those tax years (if the corporation is associated with any other corporation during the tax year)

The business limit is provided at Line 410 – Business limit. For more information about allocating the business limit among associated corporations, see Schedule 23.


For determining balance-due days, the taxable income for the previous year of corporations and associated, subsidiary, and predecessor corporations means taxable income before applying loss carrybacks.

Special rules apply to determine the balance-due day of a new corporation formed after an amalgamation, or of a parent corporation after it receives the assets of a subsidiary corporation that is winding-up. For more information, go to Payments or see Guide T7B-Corp, Corporation Instalment Guide.

Sections 125 and 157

Partnerships – Limiting deferral of corporation tax

Under section 34.2, a corporation may have to accrue additional income in respect of a partnership (other than dividends for which a deduction is available under section 112 or 113), when the fiscal period of the partnership begins in the corporation’s tax year and ends in a following tax year. The corporation is then required to accrue income under the adjusted stub period accrual (ASPA) regime for the portion of the partnership’s fiscal period that falls in the corporation’s tax year (the stub period). These rules do not affect a corporation’s capital dividend account which is to be determined without reference to section 34.2.

Since the ASPA income inclusion in a tax year is an estimate of the stub period income, the corporation is entitled to claim that same amount in the immediately following tax year. Both the ASPA income inclusion and the treatment of that same amount in the following year are subject to the characterization rules under subsection 34.2(5). They are deemed to have the same character and be in the same proportions as the partnership income that they relate to. As such, the claim in the immediately following tax year may be a deduction or a deemed allowable capital loss, whichever applies. A corporation may have ASPA in respect of more than one partnership and, in such cases, the ASPA rules apply to the corporation on a partnership by partnership basis.

In general, a corporation (other than a professional corporation) has to include in its income for a tax year its ASPA in respect of a partnership if all the following apply:

  • the corporation has a significant interest in the partnership at the end of the last fiscal period of the partnership that ends in the tax year
  • another fiscal period of the partnership begins in the tax year and ends after the tax year of the corporation
  • at the end of the tax year, the corporation is entitled to a share of an income, loss, taxable capital gain, or allowable capital loss of the partnership for the fiscal period referred to in the preceding bullet

A corporation has a significant interest in a partnership if the corporation, or the corporation, together with affiliated or related parties, is entitled to more than 10% of the partnership’s income or loss (or assets, net of liabilities, if the partnership were to cease to exist).

These rules apply to any corporation (described above), that is a member of a partnership, even if the partnership has a member that is an individual or a professional corporation that is subject to the 1995 rules limiting deferral for unincorporated businesses.

The definition of adjusted stub period accrual in subsection 34.2(1) gives the formulas for calculating a corporation’s ASPA in respect of a partnership.The ASPA formula allows the corporation to designate two reductions. The first designation concerns qualified resource expenses incurred by the partnership during the corporation's stub period. The second allows a corporate partner to make a discretionary designation to reduce its ASPA to reflect its knowledge of the actual partnership income for the stub period. Once filed, the designations cannot be amended or revoked. If the amount of the discretionary designation is too high, creating an income shortfall, the corporation may be subject to an additional income inclusion. The additional income inclusion may increase if the shortfall is above a 25% threshold.

Under certain conditions, a corporation (other than a professional corporation) that becomes a member of a partnership in a tax year may make a designation to apportion its income from the partnership between two tax years – the tax year in which the fiscal period of the partnership began and the tax year in which the fiscal period of the partnership ends.

To calculate the income inclusion under section 34.2 and, if applicable, the income shortfall adjustment and additional amount under section 34.3, use Schedule 71, Income Inclusion for Corporations that are Members of Single-Tier Partnerships, or Schedule 72, Income Inclusion for Corporations that are Members of Multi-Tier Partnerships. These are worksheets and you do not have to file them with your return. To report the amounts, file a completed Schedule 73, Income Inclusion Summary for Corporations that are Members of Partnerships, with your return.



Schedules 1, 6, and 7 are affected by the various rules in section 34.2 and the amounts reported on Schedule 73 (as applicable). For example, the amount entered on line 275 of Schedule 73 reporting the total taxable capital gains under section 34.2 must also be entered on Schedule 6.

Sections 34.2, 34.3, and 249.1


What happens if you file your return late?

If you file your return late, a penalty applies. The penalty is 5% of the unpaid tax that is due on the filing deadline, plus 1% of this unpaid tax for each complete month that the return is late, up to a maximum of 12 months.

The corporation will be charged an even larger penalty if we issued a demand to file the return under subsection 150(2), and if we assessed a failure to file penalty for the corporation in any of the three previous tax years. The penalty is 10% of the unpaid tax when the return was due, plus 2% of this unpaid tax for each complete month that the return is late, up to a maximum of 20 months.

Subsections 162(1) and 162(2)

Non-resident corporations

A non-resident corporation will be subject to a failure to file penalty equal to the greater of:

  • $100
  • $25 for each complete day that the return is late, up to a maximum of 100 days

This penalty applies if the amount calculated is more than the amount of penalty usually applied under subsections 162(1) and (2), as discussed above.

Subsection 162(2.1)

Large corporations

A large corporation has to file the T2 Corporation Income Tax Return and, if applicable, a Schedule 38, Part VI Tax on Capital of Financial Institutions. If a corporation fails to file these returns, in addition to any other penalty as applicable, we will charge a penalty for each complete month that the returns are late, up to a maximum of 40 months. The penalty will be the sum of the following amounts:

  • 0.0005% of the corporation's taxable capital employed in Canada at the end of tax year
  • 0.25% of the Part VI tax payable by the corporation [before the deductions in subsection 190.1(3)]

To identify the corporation as a large corporation, answer yes to the question at line 233 on page 2 of the return.


A corporation is a large corporation if the total taxable capital employed in Canada at the end of the tax year by it and its related corporations is over $10 million.

To determine if the total taxable capital employed in Canada of the corporation and its related corporations is greater than $10 million you can use whichever one of the following schedules that applies:

A corporation with a permanent establishment in Newfoundland and Labrador that is a financial institution, as defined under provincial legislation, has to file Schedule 305, Newfoundland and Labrador Capital Tax on Financial Institutions. See Newfoundland and Labrador capital tax on financial institutions.

Section 235

What happens if you do not comply with mandatory Internet filing?

We will charge a $1,000 penalty for non-compliance if a corporation that is required to file electronically does not comply with the requirement.

Subsection 162(7.2)

What happens if you do not report income?

We will charge a penalty if a corporation does not report an amount equal to or greater than $500 that is required to be included in computing its income on its return in a tax year and any of the three previous tax years.

This penalty will not be applied if the corporation is liable under subsection 163(2) for the same unreported amount.

The repeated failure to report income penalty is equal to the lesser of:

  • 10% of the amount you did not report on your return for the tax year
  • 50% of the difference between the understated tax payable (and certain overstated refuncable credits) related to the amount you did not report and the amount of tax withheld related to the amount you did not report

Subsections 163(1) and 163(1.1)

False statements or omissions

We will charge a penalty if a corporation, either knowingly or under circumstances of gross negligence, makes a false statement or omission on a return. The penalty is the greater of either $100 or 50% of the amount of understated tax.

Subsection 163(2)


If a corporation is charged a penalty for making a false statement or omission under subsection 163(2), the corporation cannot be charged a penalty on the same amount for failing to report income under subsection 163(1).

Misrepresentation in tax matters by a third party

We will charge a penalty if a person advises or helps another person to file a false return or knowingly allows a taxpayer to submit false tax information.

IC01-1, Third-Party Civil Penalties
Section 163.2

Cancel or waive penalties or interest

The CRA administers legislation, commonly called the taxpayer relief provisions, that gives the CRA discretion to cancel or waive penalties or interest when taxpayers are unable to meet their tax obligations due to circumstances beyond their control.

The CRA’s discretion to grant relief is limited to any period that ended within 10 calendar years before the year in which a request is made.

For penalties, the CRA will consider your request only if it relates to a tax year or fiscal period ending in any of the 10 calendar years before the year in which you make your request. For example, your request made in 2019 must relate to a penalty for a tax year or fiscal period ending in 2009 or later.

For interest on a balance owing for any tax year or fiscal period, the CRA will consider only the amounts that accrued during the 10 calendar years before the year in which you make your request. For example, your request made in 2019 must relate to interest that accrued in 2009 or later.

To make a request, fill out Form RC4288, Request for Taxpayer Relief – Cancel or Waive Penalties or Interest. For more information about relief from penalties or interest and how to submit your request, go to Taxpayer Relief Provisions.

Subsection 220(3.1)
IC07-1R, Taxpayer Relief Provisions

Voluntary Disclosures Program

Under the Voluntary Disclosures Program (VDP), you can correct inaccurate information or disclose previously omitted information. You will not be penalized or prosecuted if you make a full disclosure before we start any enforcement action or investigation against you. You will only have to pay the taxes owing plus interest.

On March 1, 2018, changes to the VDP narrowed the eligibility criteria and imposed additional conditions on applicants. For a corporation to qualify for the VDP relief based on the eligibility criteria in effect before March 1, 2018, the CRA must have received the corporation’s application with all required information, including its name, before March 1, 2018.

Two tracks were created for income tax disclosures, the Limited Program and the General Program.

The Limited Program provides limited relief for applications that disclose non-compliance where the facts suggest that there is an element of intentional conduct on the part of the corporation or a closely related party. Under this program, corporations will not be referred for criminal prosecution or charged gross negligence penalties. However, they will be charged other penalties and interest as applicable.

Under the General Program corporations will not be charged penalties and will not be referred for criminal prosecution related to the information being disclosed. The CRA will provide partial interest relief for years preceding the three most recent years of returns required to be filed.

For more details on other significant changes to the VDP, get the most recent version of Information Circular IC00-1, Voluntary Disclosures Program or go to Voluntary Disclosures Program.

If you want, you can discuss your situation first on a no-name or hypothetical basis. To speak with a CRA official, contact General Enquiries at 1-800-959-5525. For complex technical reporting issues or questions, you will be referred to a CRA official in a specialized area. This pre-disclosure discussion does not constitute acceptance into the VDP anymore.

The process of making disclosures on a no-name basis has been eliminated.

Information reporting of tax avoidance transactions

Taxpayers, advisors and promoters who engage in or who are entitled to certain fees in relation to certain tax avoidance transactions are subject to new reporting requirements.

The measures apply to certain avoidance transactions entered into after 2010, and avoidance transactions that are part of a series of transactions that started before 2011 and was completed after 2010.

Under provincial legislation, Ontario corporations are subject to the same requirements for reportable transactions entered into after May 1, 2014, or reportable transactions that are part of a series of transactions completed after May 1, 2014.

The BC government introduced updates to its anti-avoidance rule and other amendments that require corporations in BC to disclose aggressive tax avoidance transactions to the Canada Revenue Agency. This applies to a reportable transaction entered into after February 20, 2018, or a reportable transaction that is part of a series of transactions completed after February 20, 2018.

A transaction is reportable if it is an avoidance transaction as defined in subsection 245(3) of the Income Tax Act for purposes of the general anti-avoidance rule (GAAR) and has at least two of the following three characteristics:

  • the advisor or promoter has or had an entitlement to certain types of fees
  • the advisor or promoter has or had confidential protection with respect to the transaction
  • the taxpayer or the advisor or promoter (including any non-arm's length parties) has or had contractual protection for the transaction (other than as a result of certain types of fees)

A reportable transaction does not include a transaction that is, or is part of a series of transactions that includes the acquisition of a tax shelter or issuance of a flow-through share for which an information return has been filed with the minister under subsection 237.1(7) or 66(12.68) respectively.

Form RC312, Reportable Transaction Information Return, must be filed on or before June 30 of the calendar year following the calendar year in which the transaction first became a reportable transaction for the person.

If the RC312 is not filed as and when required, the reassessment period will be extended by three years after the date, if any, that the information return will have been filed. A waiver for this extended reassessment period may be filed with the CRA within this additional three year period. The scope of an assessment, reassessment, or additional assessment during the extended reassessment period for a taxpayer’s tax year is limited to the extent that it can reasonably be regarded as relating to the deduction, claim, or tax benefit.

Failure to report could result in suspension of the tax benefit, a penalty for failure to report, or both.

File this return separately from your tax return. Before you file it, make a copy for your records. Mail the original return, or amended return, and any related information to:

Winnipeg Tax Centre
Data Assessment and Evaluation Programs
Validation and Verification Section
Foreign Reporting Returns 
66 Stapon Road
Winnipeg MB R3C 3M2

Section 237.3

Country-by-country reporting

Country-by-country reporting applies to multinational enterprise groups that have a total consolidated group revenue of €750 million or more, as reflected in their consolidated financial statements in the immediately preceding fiscal year.

If the ultimate parent entity or surrogate parent entity of such a multinational enterprise group is resident in Canada, it has to file Form RC4649, Country-by-Country Report, with the CRA for fiscal years that start on or after January 1, 2016. This has to be done no later than 12 months after the end of the reporting fiscal year.

You can file Form RC4649 electronically with CRA certified software. File the form separately from your tax return. Failure to file this form could result in a penalty. The form is also available on our website. Before you send the completed form, make a copy for your records.

If you file a paper version of the form, mail the original or amended form, and any related information to:

The Canada Revenue Agency
International and Large Business Directorate
International Tax Division
344 Slater Street
6th floor
Ottawa ON  K1A 0L5

For more information, see Guide RC4651, Guidance on Country-by-Country Reporting in Canada, and Form RC4649.

Sections 162 and 233.8

What happens after you have filed your return?

After we receive your return, we send it to Corporation Services of the responsible tax centre for processing. See the list of the tax centres.

After we assess your return:

  • we send an email notification that there is mail for you to view in your secure online account, if you registered to receive e-mail notifications through My Business Account, or
  • we mail a notice of assessment

On June 25, 2018, we started sending email notifications not only when you have mail, but also when other important changes are made to your business account. If you registered for our old "Online mail" service before May 14, 2018, you are automatically registered for our “Email notifications” service. If you don’t want to receive email notifications, log into My Business Account and select "Notification preferences" to remove your email address. For more information, go to Email notifications from the CRA – Businesses.

As soon as you get the notice of assessment, compare it to your copy of the corporation's return. Contact us if you need us to clarify or explain any part of the assessment. You can call the telephone number provided in the CRA’s correspondence. If you do not have contact information, go to Contact information

Enquiries service

You can ask an account-related question online and we will provide an answer online. You can also view answers to common enquiries online.

We will try to respond within 10 business days, depending on the complexity of the question. To view the response, select the “Mail” link under the “View” tab.

With the “Enquiries service”, you can also make other online requests, such as ordering more remittance vouchers.

To access these online services, go to:

When can we reassess your return?

Within certain time limits, we can reassess your return or make additional assessments of tax, interest, and penalties. These time limits vary, depending on the type of corporation and the nature of the reassessment.

Normal reassessment period

We can usually reassess a return for a tax year:

  • within three years of the date we sent the original notice of assessment for the tax year, if the corporation was a CCPC at the end of the year or
  • within four years of the date we sent the original notice of assessment for the tax year, if the corporation was not a CCPC at the end of the year

Extended reassessment period

The normal reassessment period can be extended for an extra three years for any of the following reasons:

  • if you want to carry back a loss or credit from a later tax year
  • when a non-arm's length transaction involving the corporation and a non-resident affects the corporation's tax
  • if the corporation pays an amount or receives a refund of foreign income or profits tax
  • when a reassessment of another taxpayer's tax for any of the above reasons affects the corporation's tax
  • if a reassessment of another tax year (it must be a prior tax year if the reassessment relates to a loss or credit carryback) for any of the above reasons affects the corporation's tax
  • if the reassessment results from a non-resident corporation's allocation of revenue or expenses for the Canadian business or from a notional transaction, such as "branch advance", between the non-resident corporation and its Canadian business or
  • to give effect to the application of the non-resident trust rules in section 94 or to the application of the foreign investment rules under sections 94.1 and 94.2

For tax years of a corporation that begin after February 26, 2018, the reassessment period is extended by three years for income related to a foreign affiliate of the corporation.

Non-resident non-arm's length person (extra six years)

For losses incurred in a particular tax year that ends after February 26, 2018, the reassessment period for a preceding tax year to which those losses are carried back is extended six years beyond the normal reassessment period if both of the following apply:

  • the losses are reduced as a result of a reassessment made to the particular tax year beyond the normal reassessment period for the year
  • the reassessment to the particular tax year is made as a consequence of a transaction involving the corporation and a non-arm's length non-resident person

Provincial income reallocation (extra one year)

If the reassessment results from a provincial income reallocation, the normal reassessment period can be extended for one year from the later of:

  • the day on which the CRA is advised of the provincial reassessment
  • 90 days after the notice of the provincial reassessment was mailed

Requirements for information and compliance orders

For challenges made after the enacting legislation receives royal assent, a "stop-the-clock" rule is introduced for requirements for information served to corporations and for compliance orders.

This rule will extend the reassessment period of a corporation by the period of time during which the requirement or compliance order is contested. The period will generally start at the time the corporation challenges the requirement for information or compliance order and will end on the final disposition of the application (including any appeals).

Previously, similar “stop-the-clock” rules only applied to challenges to requirements for information that involved foreign-based information.

Unlimited reassessment period

We can reassess a return at any time for any of the following reasons:

  • the corporation has made a misrepresentation because of neglect, carelessness, wilful default, or fraud in either filing the return or supplying information required by the Income Tax Act
  • the corporation filed Form T2029, Waiver in Respect of the Normal Reassessment Period or Extended Reassessment Period, with a tax services office before the normal reassessment period expires. Form T2029 can be filed up to three more years after the end of the normal reassessment period if the waiver applies to one of the situations previously described under Extended reassessment period
  • the reassessment is to carry back losses or certain tax credits and deductions where a prescribed form requesting the amendment has been filed on time
  • a court instructs us to reassess


If you want to revoke a waiver that was previously filed to extend the normal reassessment period for a certain tax year, file Form T652, Notice of Revocation of Waiver, at your tax services office. The revocation will take effect six months after you file Form T652.

Sale or disposition of real estate

The CRA may at any time reassess an income tax return beyond the normal reassessment period for any of the folowing reasons:

  • the corporation does not report in its income tax return a sale or other disposition of a real or immovable property that is capital property of the corporation
  • the corporation does not file an income tax return but the CRA issues an assessment of tax (for example, after a review of a corporation that did not file a return)
  • the corporation owned the capital property directly or indirectly through a partnership and the partnership did not report the sale or other disposition in the partnership information return

Under this extended reassessment period, the reassessment is limited to amounts reasonably relating to the unreported or previously unreported disposition of real or immovable property that is capital property of the corporation or partnership, as the case may be.

If the corporation does not report the disposition in its initial return for the tax year, but later amends its return (for example by filing a request for adjustments under subsection 245(6)), the CRA may still make a reassessment outside of the normal reassessment period within three years of the amendment being filed.

Subsections 152(3.1), 152(4), and 152(4.1)
IC75-7, Reassessment of a Return of Income

How to request a reassessment

You can request a reassessment electronically using the latest commercial tax preparation software packages, or send a letter to the tax centre that serves the corporation. If you send a letter, state the name of the corporation, the business number, the tax year, and any details that apply. With your letter, include any relevant supporting information, such as revised financial statements and schedules. If you are preparing your return using tax preparation software, submit the bar codes that contain the information needed to reassess your return. Do not send the entire T2 return.

To ask to carry back a loss or tax credit to a prior tax year, file whichever of the following schedules apply:

You can file these schedules with the return on which you report the loss or earned the credit, or you can forward them separately to the tax centre that serves the corporation.

Subsection 152(6)

How to register a formal dispute

Many misunderstandings are caused by a lack of information or by a simple miscommunication. That's why we say: “Talk to us”.

If you have new or additional information, you or your authorized representative can ask for a change online at My Business Account, Represent a Client, or by writing to us. Many disputes are resolved this way.

If you disagree with an assessment or a determination, you can make a formal objection.

Filing an objection is the first step in the formal process of resolving your dispute. You have 90 days after the date of the notice of assessment or determination to file an objection.

You can file an objection:

In all cases, you have to explain why you disagree and include all relevant facts and supporting documents.

For large corporations, your objection must:

  • reasonably describe each issue
  • specify for each issue the relief you are seeking, expressed as the amount of a change in the income, taxable income, loss, taxes payable, refundable amounts, and overpayments or balance of unclaimed outlays, expenses, or other amounts of the corporation
  • provide facts and reasons the corporation relied on for each issue

Section 165

A large corporation that objects to an assessment will have to pay 50% of the disputed amount. A corporation is a large corporation if the total taxable capital employed in Canada at the end of the tax year by the corporation and its related corporations is over $10 million. The corporation also has to pay the full amount of taxes not in dispute.

Subsection 225.1(7)

For more information about objections and appeals, see Pamphlet P148, Resolving your dispute: Objection and appeal rights under the Income Tax Act, or go to Complaints and disputes.

Disputing loss determinations

The formal process of resolving a dispute does not usually apply to loss amounts under dispute, because there is no tax, interest, or penalty involved.

However, a corporation may request a loss determination if it does not agree with the amount of the losses assessed by the CRA. The CRA will determine the amount of the loss and confirm in writing by issuing Form T67AM, Notice of Determination/Redetermination of a Loss.

Once the corporation has received the notice of determination, it can file an objection within 90 days after the date of the notice.


You cannot request a loss determination if the CRA assessed your loss to be the same as what you reported.

If the corporation asks, we will make determinations of the following amounts:

  • a non-capital loss
  • a net capital loss
  • a restricted farm loss
  • a farm loss
  • a limited partnership loss

Send any requests for loss determinations to your tax services office or tax centre.

Subsections 152(1.1) and 152(1.2)

Keeping records

Keep your paper and electronic records for a period of six years from the end of the last tax year that they relate to. If you file your income tax return late, keep your records for six years from the date you file your return.

Certain records must be kept longer. These include minute books, which have to be kept until sometime after dissolution. However, if you want to destroy your records early, complete Form T137, Request for Destruction of Records.

For more information, go to Keeping records.

Subsections 230(4), 230(4.1), 230(5), and 230(6)
Regulation 5800
IC78-10, Books and Records Retention/Destruction

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