What Happens If You Don't Register for GST/HST in Canada
Crossed $30,000 without registering for GST/HST? The CRA can back-date registration and assess tax you never charged, plus penalties and interest.
Claim GST/HST input tax credits in Canada: who can claim, the documents the CRA requires at $100 and $500, the four-year claim window, the 90 percent commercial-use rule, and the purchases that never qualify.
Applies in: across Canada
An input tax credit lets a GST/HST registrant recover the GST/HST paid on business purchases, but only when five conditions all hold. You must be registered in the period the tax became payable, the purchase must be for your commercial activities, you must have the supporting document in hand before you claim, the tax must have been payable or properly paid, and the claim must be made inside the time limit. Miss any one of those, and the credit is not claimable on that return, even if the purchase was plainly for the business. Most of the work is therefore paperwork discipline: keep the invoice, check the supplier number where the rules require it, and claim the credit on a return inside four years rather than letting old receipts pile up.
This guide covers the process only. It is not advice about whether a particular purchase of yours qualifies. Where a purchase sits near a boundary, such as a vehicle, a home office, or a mixed personal and business expense, the CRA memoranda and a ruling request are the routes to certainty, not a general guide.
Input tax credits belong to registrants. The CRA states the test plainly in GST/HST Memorandum 8.1: the person must be a registrant during the reporting period in which the GST/HST on the property or service becomes payable, or is paid without having become payable. Registration that starts later does not retroactively make earlier purchases claimable in the ordinary way, and a person who has stopped being a registrant cannot keep claiming credits for later purchases.
Check your registration effective date in My Business Account before you assume a purchase qualifies. If you registered voluntarily below the $30,000 small-supplier threshold, you became eligible to claim credits from the effective date of registration, subject to the other conditions. If you were required to register because taxable supplies crossed $30,000 over four consecutive calendar quarters, the effective date the CRA assigned is the date that matters, not the date you noticed the threshold had passed.
The property or service must be acquired, imported, or brought into a participating province for consumption, use, or supply in the course of your commercial activities, and the credit is available only to the extent of that use. Commercial activity means a business carried on by the person, apart from the making of exempt supplies. That distinction does most of the work in practice. The amount claimed must also be reasonable in the circumstances, in quality, nature, and cost in relation to the business.
Purchases used to make exempt supplies do not generate input tax credits to the extent of the exempt use. A registrant who makes both taxable and exempt supplies apportions. A purchase used entirely for personal purposes generates no credit at all. The CRA's GST/HST Memorandum 8.2 is explicit that property or services acquired exclusively for the personal consumption, use, or enjoyment of an employee, officer, or their relatives are restricted, and that memberships in clubs whose main purpose is dining, recreational, or sporting facilities are restricted unless the membership is acquired exclusively for resale in the ordinary course of a business of selling such memberships.
Apply the apportionment test honestly and keep a note of how you worked it out. Where 90 percent or more of the consumption or use of a property or service is in the course of commercial activities, a registrant other than a financial institution may claim an ITC equal to 100 percent of the GST/HST paid or payable. Below that level, the claim follows the commercial-use portion, and the method you use must be fair and reasonable for the purchase. A vehicle, a phone, and a home office each need their own use record, because the same percentage rarely fits all three.
Before filing the return that claims the credit, you must obtain sufficient documentary evidence that lets the amount of the credit be determined. An invoice, receipt, credit card receipt, debit note, book or ledger entry, written contract, or computerized record can serve, provided it contains the prescribed information for the size of the purchase. The thresholds changed effective April 20, 2021, from $30 and $150 to $100 and $500 — the change is set out in the CRA's Excise and GST/HST News No. 118 — and older guides still quote the old figures. Use the current thresholds.
For a total amount paid or payable under $100, the supporting document must include the supplier or intermediary name or trading name, the date of the invoice or the date the tax was paid or payable, and the total amount paid or payable. For $100 to $499.99, it must also indicate the GST/HST charged or that the amount includes GST/HST at the applicable rate, indicate the status of each supply where taxable and exempt supplies appear together, and show the supplier GST/HST registration number. For $500 or more, it must also show your name or trading name, a brief description of the property or services, and the terms of payment.
If a document is missing the supplier registration number on a purchase of $100 or more, ask the supplier for a corrected document before you claim. The CRA can deny a claim that lacks the prescribed information, and reconstructing it months later, after a supplier has closed or changed systems, is the common reason credits are lost. Verify a supplier number with the CRA GST/HST Registry before you rely on it for a large purchase, and keep the registry result with the invoice.
Claim input tax credits in the total input tax credits calculation on your GST/HST return for the reporting period, or on a later return filed inside the time limit. A missed credit from an earlier period is not automatically lost: in most cases you can claim it on a later return, provided that later return is filed by the due date of the return for the last reporting period ending within four years after the end of the period in which the credit arose.
Specified persons have a shorter window. Generally, the four-year limit is reduced to two years for a specified person, which includes a listed financial institution and a person whose threshold amounts exceed $6 million for both the fiscal year that includes the reporting period and the previous fiscal year, with exceptions for charities and for persons whose supplies are all or substantially all taxable. The two years run from the end of the fiscal year that includes the reporting period in which the credit arose, not from the end of that reporting period. If your business is near that size, treat the two-year window as the working deadline and do not assume the general four-year rule applies.
Do not send receipts with an electronic return. The CRA does not ask for them at filing, but it can ask for them on review or audit, and the documents must already be in your records when the claim is made. Keep purchase invoices and receipts with your GST/HST records, which must be available to the CRA when it asks to see them, and keep them in a form that lets you find the document for a given return period without rebuilding the file.
Several categories need a second look before the return is filed.
Meals and entertainment come first for most small businesses. You may claim input tax credits on food, beverages, and entertainment expenses incurred in the reporting period, but you must then make an adjustment to recapture 50 percent of the input tax credits previously claimed on those expenses — under GST/HST Memorandum 8.2, the recapture goes in the first reporting period after the end of the fiscal year in which the expenses were incurred. Claiming the full amount and forgetting the recapture is a common error, and the adjustment belongs in the return calculation, not in a note to yourself.
Home office expenses are restricted by a separate rule. No input tax credit is available for property or services acquired for consumption or use in relation to a work space in a self-contained domestic establishment where the registrant resides, unless the work space is the principal place of business or is used exclusively to earn business income and on a regular and continuous basis for meeting clients, customers, or patients. Expenses for the home as a whole, such as heat and electricity, are apportioned, and expenses for rooms with no business use are excluded.
Passenger vehicles and aircraft carry their own capital property rules, including limits tied to the capital cost limitation for income tax purposes. Do not assume the full tax on a vehicle is claimable because the vehicle is used for the business. Check the CRA guidance for passenger vehicles before claiming, and keep a use log that supports the percentage you claim.
Large businesses in Ontario should also know that the recapture of input tax credits for specified property and services in Ontario was phased out — the CRA's GST/HST Info Sheet GI-171 sets the recapture rate at 0 percent for the provincial part of the HST becoming payable on or after July 1, 2018. If an older reference tells you to report recaptured credits for Ontario at a positive rate, it is describing the phase-out period, not the current position. The adjustment form still exists for the cases it covers, including Schedule B for recaptured input tax credits, so confirm on the current return form whether any recapture line applies to your period rather than assuming it does.
An input tax credit is the GST/HST a registrant recovers on property or services acquired for use in commercial activities. You deduct eligible input tax credits from the GST/HST you collected, and the difference is the net tax you remit or the refund you claim. The credit is not a deduction from income; it is part of the GST/HST return calculation.
A GST/HST registrant can claim input tax credits if the property or service was acquired for consumption, use, or supply in the course of commercial activities, the registrant was a registrant in the reporting period when the tax became payable or was paid, sufficient documentary evidence was obtained before the claim, and the claim is made within the time limit. A person who is not registered cannot claim input tax credits.
Most registrants have four years. The credit must be claimed in a return filed by the due date of the return for the last reporting period ending within four years after the end of the reporting period in which the credit arose. Specified persons, which include listed financial institutions and persons whose threshold amounts exceed $6 million for both the fiscal year that includes the reporting period and the previous fiscal year, generally have two years instead, counted from the end of that fiscal year.
You need sufficient documentary evidence that lets the amount of the credit be determined, obtained before you file the return claiming it. For a total sale under $100, the document must show the supplier name, the date, and the total amount. From $100 to $499.99 it must also show the GST/HST charged or included and the supplier GST/HST registration number. At $500 or more it must also show your name, a description of the property or services, and the terms of payment.
You can claim the input tax credit when the expense is incurred, but you must then recapture 50 percent of the input tax credits claimed on food, beverages, and entertainment expenses. The recapture is an adjustment in the appropriate reporting period, and it parallels the income tax treatment of meals and entertainment. Charities and public institutions are treated differently under the simplified calculation rules, so check the CRA guidance for your type of organization before applying the general rule.
Only to the extent of the commercial use. Where 90 percent or more of the consumption or use of a property or service is in the course of commercial activities, a registrant other than a financial institution may claim 100 percent of the GST/HST paid. Where use is mixed below that level, apportion the claim. Property or services acquired exclusively for personal consumption or enjoyment do not qualify, and club memberships for dining, recreational, or sporting facilities are restricted.