Fees for advance income tax rulings and pre-ruling consultations

For detailed information about the requirements when requesting an advance income tax ruling or a pre-ruling consultation (collectively, Rulings), please refer to the current version of Income Tax Information Circular IC70-6.

Income Tax Rulings Directorate fees

The Directorate provides the Rulings service on a cost recovery basis. This means that its practice is to pass the costs associated with the provision of Rulings to those who request the service.

The Directorate charges a fee for each hour or part hour worked on a Ruling request. All fees are subject to applicable taxes.

As a replacement for the Directorate’s initial and regular hourly rates, an increase to the Directorate’s hourly base fee has been approved by Order in Council in the Advance Income Tax Ruling Fees Order. This change will bring the Directorate’s hourly base fee into alignment with the actual costs to deliver these services. The new base fee will be introduced in two phases, beginning on April 1, 2022 and again on April 1, 2023. Pursuant to section 17 of the Service Fees Act, the new base fee will be adjusted in accordance with the Consumer Price Index (CPI) beginning on April 1, 2024.

The hourly fees for the Directorate’s services are as follows:

Fees payable for Rulings
Period in which work is performed  Hourly base fee for the period Hourly base fee with CPI adjustment
2023-04-01 to 2024-03-31 $281.22 N/A
2022-04-01 to 2023-03-31 $221.24 N/A
2021-04-01 to 2022-03-31 $100 for each of the first 10 full or partial hours (initial rate); $155 for subsequent full or partial hours (standard rate)  $104.04 initial rate
$161.26 standard rate

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