Canadian Commodity Tax

The Canadian Commodity Tax Committee is responsible for TEI’s advocacy and educational efforts in Canadian federal and provincial excise, sales, and use tax matters.

The committee provides comments on legislative and administrative proposals and conducts annual liaison meetings with the Canada Revenue Agency and Canadian Department of Finance to discuss tax-enforcement and policy matters in the commodity tax field.

TEI’s Canadian Income and Commodity Tax Committees Seek Member Input for 2021 Liaison Meetings

The members of TEI’s Canadian Income Tax and Canadian Commodity Tax committees are actively preparing for the Institute’s 2021 liaison meetings in Ottawa, and they seek your input in developing this year’s meeting agendas.


Staff Liaison:

Kelly Madigan,Tax Counsel


Canadian Budget 2024 Expanded CRA Audit Powers - TEI Comments

On May 29th, 2024, TEI filed comments with Canadian Minister of Finance Chrystia Freeland regarding Budget 2024's proposed expanded Canada Revenue Agency audit powers. TEI's comments focused on the substantial negative impact the proposals would have on taxpayers generally and taxpayer rights specifically. TEI's letter included several recommendations on how the expanded powers proposals could be improved and lessen their impact on Canadian taxpayers. TEI's comments were prepared under the aegis of its Canadian Income Tax Committee, whose Chair is Steve Saunders of Atco. Benjamin R.

TEI Submits Comments on New GST/HST Joint Venture Election Rules

On March 15, 2024, TEI submitted comments on the new GST/HST joint venture ("JV") election rules to the Department of Finance in response to a request for comments in the November 21, 2023, Fall Economic Statement. TEI's comments addressed concerns that the proposed legislation is too restrictive, cumbersome and administratively burdensome. TEI requests that the JV election criteria focus on practicality and ease of administrability and compliance.

Read the comments here.

TEI Submits Comments on 2024 British Columbia Budget Changes to the Provincial Sales Tax Definition of “Software”

On March 29, 2024, TEI provided a submission to the British Columbia ("BC") Minister of Finance in response to the 2024 BC provincial budget and accompanying bill that introduce changes to the definition of “software” for purposes of the BC provincial sales tax. TEI's comments addressed concerns over retroactive legislation and the breath of the Ministry's definition of "software," among other issues.

Read the submission here.

TEI Provides Submission in Response to British Columbia 2023 Consultation on PST Application for Partnerships

On December 23, 2023, TEI provided a submission to the British Columbia ("BC") Minister of Finance as part of the 2023 Consultation on the Provincial Sales Tax Application to Partnerships. TEI's comments included support for the transition to recognize BC partnerships as separate legal persons for purposes of PST and a recommendation that certain rules for partnerships mimic those for corporations.

Read the submission here.

TEI Holds 2023 Liaison Meetings with Canada Revenue Agency and Department of Finance

On December 5-6, 2023, a delegation of the Canadian Commodity Tax Committee members participated in TEI's annual liaison meetings with representatives of the Canada Revenue Agency (“CRA”) and Department of Finance. The 2023 meetings featured robust agendas covering a range of tax law, policy, and administration issues of importance to many TEI members. Official written responses to many of TEI’s questions are expected from CRA.

TEI Receives Responses to 2020, 2021, and 2022 Liaison Meeting Questions from the Canada Revenue Agency

In December of 2020, 2021, and 2022, a delegation of Canadian Commodity Tax Committee members met with representatives of the Canada Revenue Agency and Department of Finance. The Canada Revenue Agency has issued their responses to TEI’s liaison meeting questions, which cover a range of important tax law, policy, and administration issues. TEI also provided questions to the Department of Finance, although Finance does not provide written responses.

Read the files:

TEI Comments on Canadian Digital Services Tax

On September 8, 2023, TEI submitted comments on a revised draft of the Canadian Digital Services Tax (DST) to Canada's Department of Finance.

TEI Canadian Commodity Tax Comments and Liaison Meeting with British Columbia Ministry of Finance

In preparation for a liaison meeting between members of the TEI Canadian Commodity Tax Committee and the British Columbia(“BC”) Ministry of Finance on June 27, 2023, TEI submitted comments on a number of issues relevant to that province.