Non-resident sellers in Canada face a different GST/HST registration path: permanent establishment, the security deposit, the non-resident registration form, and the tax centre that handles the file.
Applies in: across Canada
This guide covers the normal GST/HST registration regime for non-resident sellers: businesses located or incorporated outside Canada that make taxable supplies in Canada. It is distinct from the guide on registering for GST/HST as a resident business, which assumes a Canadian business number, a Canadian address, and the standard Business Registration Online route. The non-resident route differs in three places that matter before any sale is made: whether registration is required at all, whether security must be provided, and which tax centre holds the file. A third regime, the simplified registration for cross-border digital products and services, is covered separately in the guide on online and digital sales, and the two regimes cannot be held at the same time.
Registration follows activity in Canada, not the seller's home address alone. The CRA states the general position in its guide for non-residents: a non-resident does not have to register under the normal registration provisions if the non-resident does not carry on business in Canada, and a non-resident whose only commercial activity is selling taxable real property located in Canada otherwise than in the course of a business also does not have to register under the normal provisions. The exception is narrow and specific: a person who enters Canada to make taxable supplies of admissions for a place of amusement, a seminar, an activity, or an event must apply for registration before making any such supply.
Carrying on business in Canada is therefore the threshold question, and it is a facts question, not a label. Selling goods stored in a Canadian fulfillment warehouse, selling through a Canadian fixed place of business, or regularly supplying services performed in Canada can amount to carrying on business here, while a single sale shipped from abroad to a Canadian buyer may not. This guide does not decide that question for any seller; the CRA's non-resident tax centre is the place to confirm it, and the seller should confirm it before the first Canadian supply, because the registration duty, once triggered, is backdated to the date the threshold was crossed.
Permanent establishment is the concept that decides whether a non-resident is treated as resident for GST/HST purposes, and whether security is required. The Excise Tax Act definition, as the CRA reproduces it, covers two cases: a fixed place of business of the particular person through which the person makes supplies, and a fixed place of business of another person, other than a broker, general commission agent, or other independent agent acting in the ordinary course of business, who is acting in Canada on behalf of the person and through whom the person makes supplies in the ordinary course of business.
The consequences follow the definition. A non-resident with a permanent establishment in Canada is considered resident in Canada, but only for the activities carried on through that permanent establishment. For taxable supplies made through it, the person registers under the normal rules as a resident person and collects tax on taxable supplies made in Canada, unless the person is a small supplier. Security still applies in the case the CRA memorandum singles out: a non-resident with a permanent establishment who does not make supplies through its own fixed place of business, and who makes supplies only through another person's fixed place of business, must provide and maintain security. A website or server located in Canada does not automatically create a permanent establishment; the CRA's electronic commerce guidance flags that exact question as one that depends on the facts, and a seller relying on Canadian computer equipment should get a ruling rather than assume either answer.
The small-supplier threshold is $30,000 of taxable supplies, and for a non-resident it is tested on taxable supplies in Canada, not on worldwide revenue. The general rule counts taxable supplies, including zero-rated supplies, over the previous four calendar quarters and the current quarter. While the total stays at or below $30,000, the seller is a small supplier and is not required to register, unless an exception such as the admissions rule or the taxi and ride-sharing rule applies. Once the threshold is crossed, registration is required, and the effective date of registration is set by the registration rules, which can backdate it to when the seller stopped being a small supplier.
Voluntary registration is open to a small supplier engaged in a commercial activity in Canada. A non-resident who registers voluntarily faces the same security question as a non-resident who must register, so the decision to register early should be taken with the security amount in hand, not after the fact. Keep a running total of taxable supplies made in Canada, by quarter, with the invoices that support it. The threshold is easy to cross unnoticed when sales are spread across platforms, because the total is the seller's, not the platform's.
Non-resident registration does not go through the standard Business Registration Online flow used by resident businesses. The CRA directs non-residents to the Non-resident Business Registration online form where any of four conditions applies: the business is incorporated outside Canada, the business is located outside Canada, the owner's Social Insurance Number starts with 0, or the owner does not have a Social Insurance Number. The form registers the business number and the CRA program accounts, including the GST/HST account.
The file is held by the Non-Resident Registration and Security Section. The tax centre to contact depends on the physical location of the business outside Canada; where the physical business location is within Canada, the non-resident tax centre closest to where the business is conducted applies, namely the Prince Edward Island Tax Centre or the Sudbury Tax Centre. The published mailing address for the section is the Atlantic Tax Centre, 275 Pope Road, Summerside, Prince Edward Island, C1N 6A2. Telephone enquiries go to 1-866-453-0452 toll-free in Canada and the United States, or collect at 1-613-221-3039 from elsewhere, Monday to Friday, 8:30 a.m. to 4:30 p.m. Eastern Time. A callback from a non-resident business tax specialist can be requested online, with a response within three business days. The form is available 21 hours a day, unavailable from 3:00 a.m. to 6:00 a.m. Eastern Time for maintenance. In Quebec, registration and enquiries for the GST and the Quebec sales tax go to Revenu Québec.
Security is the part of non-resident registration that surprises sellers, because it is a condition of registration, required at the time of registration, not an annual fee. The general rule, in the CRA's security memorandum, is that with few exceptions, a non-resident without a permanent establishment in Canada who is required to register, or who applies voluntarily, must provide and maintain security in an amount and form satisfactory to the Minister, to ensure the person pays or remits all amounts payable under the GST/HST legislation.
The amount is formulaic. For the first year, it is 50 percent of estimated net tax, whether positive or negative, during the 12-month period after registration. For following years, it is 50 percent of actual net tax, whether positive or negative, for the last 12-month period. The maximum security is $1,000,000 and the minimum is $5,000. The exception is also formulaic: security is not required if the estimate of taxable sales, leases, or other supplies in Canada is $100,000 or less annually and annual net tax will be between $3,000 remittable and $3,000 refundable. A seller whose estimate sits near either boundary should document the estimate, because the exception turns on it.
The form of security is restricted to one of cash, a certified cheque, a money order, or a qualifying bond. All security deposits are payable in Canadian dollars. Cash or cash equivalents may be used to pay other outstanding debts to the CRA at the time the security is released, and the CRA does not accept non-transferable bonds such as Canada Savings Bonds. For the current security requirements, the CRA directs sellers to their tax services office or tax centre, which is the right route where the formula produces an amount the seller disputes or where the estimate changes materially during the year.
Once registered, a non-resident registrant charges GST/HST on taxable supplies made in Canada at the rate for the place of supply, files GST/HST returns, and claims input tax credits for GST/HST paid on purchases related to commercial activities, under the same return mechanics as a resident registrant. The rate charged follows the customer's province for goods and services under the place-of-supply rules, which the guide on charging GST/HST covers in full. The non-resident registration does not change the rate; it changes how the account was opened and what security stands behind it.
Closing an account follows the normal route, with one additional step. The account can be closed online through My Business Account or Represent a Client, or by mail on Form RC145, sent to the tax centre within six months of signing. A non-resident business that provided security when it registered must inform the Non-Resident Registration and Security Section when closing the account. The security release follows the settlement of the account, and any other amounts owing to the CRA can be taken from cash security at release. Do not treat the closure as complete until the section confirms it, because the security, not the online closure notice, is the outstanding item.
No. The CRA states that a non-resident does not have to register under the normal registration provisions if the non-resident does not carry on business in Canada, except for a person who enters Canada to make taxable supplies of admissions for a place of amusement, a seminar, an activity, or an event, who must apply for registration before making any such supply. A non-resident whose only commercial activity is selling taxable real property in Canada otherwise than in the course of a business is also listed as not having to register under the normal provisions. Once a non-resident does carry on business in Canada and makes taxable supplies here, the normal registration rules apply, including the small-supplier threshold. The digital-economy measures for cross-border digital products and services use a separate simplified registration regime, covered in the online and digital sales guide.
A fixed place of business of the person through which the person makes supplies, or a fixed place of business of another person, other than a broker, general commission agent, or other independent agent acting in the ordinary course of business, who is acting in Canada on behalf of the person and through whom the person makes supplies in the ordinary course of business. A non-resident with a permanent establishment in Canada is considered resident in Canada, but only for the activities carried on through that permanent establishment, and is required to register as a resident person for taxable supplies made through it, unless the person is a small supplier. A non-resident with a permanent establishment who does not make supplies through its own fixed place of business, and who makes supplies only through another person's fixed place of business, must still provide security.
It is tested on taxable supplies made in Canada. A person is a small supplier while taxable supplies, including zero-rated supplies, do not exceed $30,000 over the previous four calendar quarters and in the current quarter, under the general small-supplier rule the CRA applies in its registration guidance. Once the threshold is crossed, the person stops being a small supplier and must register, with an effective date set by the registration rules. Supplies facilitated by a registered distribution platform operator that is deemed to have made the supply are excluded from a non-resident vendor's digital threshold, but that exclusion belongs to the digital-economy regime, not to the normal registration of goods sellers. Keep a running 12-month total of taxable supplies in Canada, not worldwide sales.
Generally, a non-resident without a permanent establishment in Canada who is required to register, or who applies voluntarily, must provide and maintain security, as a condition of registration, at the time of registration. The initial amount is 50 percent of estimated net tax, whether positive or negative, for the 12 months after registration; in later years it is 50 percent of actual net tax for the previous 12 months. The maximum is $1,000,000 and the minimum is $5,000. Security is not required if the estimate of taxable sales, leases, or other supplies in Canada is $100,000 or less annually and annual net tax will be between $3,000 remittable and $3,000 refundable. Security may be cash, a certified cheque, a money order, or a qualifying bond, is payable in Canadian dollars, and the CRA does not accept non-transferable bonds such as Canada Savings Bonds.
Through the Non-resident Business Registration online form, where any of four conditions applies: the business is incorporated outside Canada, the business is located outside Canada, the owner's Social Insurance Number starts with 0, or the owner does not have a Social Insurance Number. The form registers the business number and CRA program accounts, including the GST/HST account. Questions go to the Non-Resident Registration and Security Section at the Atlantic Tax Centre in Summerside, Prince Edward Island, by mail, by fax at 519-971-2011, or by telephone toll-free in Canada and the United States at 1-866-453-0452, or collect from outside Canada and the United States at 1-613-221-3039, Monday to Friday, 8:30 a.m. to 4:30 p.m. Eastern Time. A callback from a non-resident business tax specialist can be requested through the CRA's online form, with a response within three business days.
The non-resident must inform the Non-Resident Registration and Security Section if security was provided when the GST/HST account was opened. Closing itself follows the normal route, online through My Business Account or Represent a Client, or by mail on [Form RC145](https://www.canada.ca/en/revenue-agency/services/forms-publications/forms/rc145.html), Request to Close Business Number Program Accounts, sent to the tax centre within six months of signing. Cash or cash equivalents used as security may be used to pay other outstanding debts to the CRA at the time the security is released, so the file should be clear of other amounts owing before the release is expected. In Quebec, non-resident registration questions go to Revenu Québec, not the CRA.
Where a point could not be verified on a Canada Revenue Agency page at the time of writing — whether a particular seller carries on business in Canada, whether a particular website or server arrangement creates a permanent establishment, and the current security requirement for a specific file — this guide states the CRA's test and directs the reader to the Non-Resident Registration and Security Section instead of deciding the point. No agent or representative requirement is stated in this guide, because none was verified on a CRA page at the time of writing; confirm representation arrangements with the tax centre before appointing one.