Validating GST & QST numbers represents only one step...

Validating GST & QST numbers represents only one step in establishing whether a person is entitled to claim an input tax. Other elements to consider are:

• Who is the recipient of the good or the service acquired?
• Is the good or the service acquired for consumption, use or supply in the course of commercial activities of the person?
• Is the information contained on the invoice or the contract as per the regulations?

Do not hesitate to submit to us your contracts in order to establish who is entitled to claim the GST-HST & QST and as the case maybe, bring forward an action plan.

1. GST and QST Registries

Both the Canada Revenue Agency (CRA) and Revenu Québec (RQ) are providing an access to their database for validating the GST and the QST registration numbers respectively.

You can consult online the Canada Revenue Agency's database in order to validate the GST registration number.

You can consult online Revenu Québec's database in order to validate the QST registration number.

2. Prescribed Input Tax Credit Information (GST/HST)

Paragraph 169(4)a) of the Excise Tax Act and section 201 of An Act respecting the Québec sales tax provide that a registrant may not claim an input tax credit (ITC) or an input tax refund (ITR) for a reporting period unless, before filing the return in which the ITC or the ITR is claimed, the registrant obtains the required prescribed information.

It is interesting to note that the regulations do not require that all the required information be on a single document. During an APFF symposium, a Revenu Québec representative confirmed that the prescribed information could be displayed on different documents as long as those documents are all available at the time the claim is made.

The prescribed information in the regulations is notably to the effect that the registration number has to be provided on sales of $30 or more prior to April 20th, 2021 and $100 or more after April 19th, 2021

Both the CRA and RQ have disallowed ITCs or ITRs claimed by registrants on purchases where the registration number provided by their suppliers was not valid.

In the case Systematix Technology Consultants Inc. v. The Queen, 2007 FCA 226, the court confirmed that the ITC claimed by the registrant should be disallowed since the GST registration numbers provided by the suppliers were not valid. In this case, the trial judge has determined that the registration number should be valid at the time the supply is made or when the claim is made, while the claim could be disallowed if the registration number has been revoked or is not valid at these times.

3. QST Extension Number

The QST registration number has 16 characters: ten digits, followed by the letters TQ and four more digits.

The six last characters are notably used to identify divisions of a given corporation. The last 4 digits of the registration number is seldom provided by suppliers, however you should note that the extension TQ0001 is the more commonly used.

The search engine will first process only the first ten digits. Should the other characters be needed, you will be notified.

Revenu Quebec stated that, when the last characters have not been provided by the suppliers, registrants should simply contact them to obtain the extension numbers.

4. QST Registration Number of an SLFI

If the QST registration number is made up of only nine digits, does not include “TQ” and is the same as the GST/HST registration number, this means the business is a selected listed financial institution (SLFI). In such a case, the QST registration is administered by the CRA. To validate such a QST registration number, contact the CRA at 1 800 959-5525.

5. Digital Economy - Non resident - The Simplified GST Regime & the Specified QST System

Some GST and QST registration numbers may not give rise to an input tax. This situation will occur when dealing with the digital economy performed by non resident vendors who are registered under the GST simplified regime, and under the specified QST system, even if the goods and services are acquired in the course of commercial activities. Both the Canada Revenue Agency and Revenu Quebec have allowed these foreign entities to collect and remit tax under a special fast track registration program. These special sales tax registration statuses are notably made available to cross border digital vendors and platform based operators of short term accommodation. A QST registration number that would include the letters NR identifies these problematic entities, while a QST registration number with the letters TQ would not.

You can contact us to inquire whether you can claim theses taxes back directly from your foreign supplier.