Who this is for
- GST/HST registrants billed GST/HST on ads by a platform outside Canada
- Unregistered, small-supplier and exempt-only businesses billed the same tax
- Agencies and others who buy ads for clients
Not covered here
- Québec sales tax (QST) and provincial sales taxes
- What an invoice must show to support an input tax credit
- Charging GST/HST on ad spend rebilled to clients
- The seller's side: when a foreign platform must register
- Income tax treatment of advertising costs
Why did an ad platform charge me HST, and does my GST/HST number stop it?
A platform outside Canada that is registered under the simplified system charges GST/HST on a service when the buyer's usual place of residence is in Canada and the buyer has not given satisfactory evidence of an ordinary GST/HST registration. The Act calls that buyer a specified Canadian recipient, which includes an unregistered business and a registered one that never gave its number. When a registered business gives the platform its number, the CRA says the platform is not required to charge it.
Foreign online sellers register under a simplified GST/HST system, and the CRA publishes their names. The seller's side is in non-resident and digital sellers. An input tax credit is how a registered business subtracts the GST/HST it paid on purchases from the GST/HST it collected.
The rate follows your province (GST alone in some, HST in others), so your percentage may differ from the Ontario example below. This page covers federal tax only; Québec sales tax (QST) is separate.
Three things make a case not simple:
- Who billed you. A non-resident on the CRA's simplified list follows these rules. A supplier registered the ordinary way, including a Canadian entity, follows ordinary credit rules.
- When your registration took effect. For invoices from before you gave your number, CRA Notice 322 says a buyer registered the ordinary way can ask the platform for a refund by showing its registration was in effect when the supply was made. Keep that proof as well as the date you gave the platform your number.
- Whether you can register at all. A business that is not registered, or makes only exempt supplies, has no number to give.
The CRA's examples of digital products and services do not name advertising, so do not assume. On your ad invoice, find the legal name of the company that billed you and whether it shows a tax line, then look that name up on the CRA list. Other online services a non-resident sells you, such as apps and subscriptions, follow the same test.
| Your situation | Can you avoid the charge? | Can you get the tax back? |
|---|---|---|
| Registered; gave your number; invoice shows no tax | Yes. Keep proof of the date you gave it | Nothing to recover |
| Registered; platform charged tax after you gave your number | The platform is not required to charge you | Ask the platform for a refund. The CRA says this tax is not recoverable by input tax credit or the paid-in-error rebate |
| Registered; never gave your number; non-resident supplier on the simplified list | Give your number now to stop new charges | The CRA says tax already paid cannot be claimed as an input tax credit or rebate. You may ask the platform for a refund, showing you were registered when the supply was made |
| Registered; invoice from a supplier registered the ordinary way | Ordinary rules apply | An ordinary input tax credit, if the invoice supports it, the ads serve your commercial activities and you do not use the Quick Method |
| Not registered | No number to give | Generally no credit; the tax is usually a cost |
| Only exempt supplies | Generally cannot register | Generally no credit; the tax is usually a cost |
To find your row, gather the invoices (billing entity, tax shown, dates), your registration number, and proof of the date you gave it to the platform.
Each invoice has its own clock: the platform's window to refund tax is 2 years from the day it was charged, so the oldest months drop out first.
Which number do I give, and how do I check the supplier?
Give the platform your own GST/HST registration number, the one belonging to the business that is its customer. It has 15 characters: your nine-digit business number, the letters RT, and a four-digit account number, as in 123456789 RT 0001 (CRA: RC4022). The number on the platform's invoice is the supplier's, a different number.
The number must belong to whoever the platform's customer is, because the Act asks whether the recipient has shown that it is registered (Act, s. 211.1). If the ad account is in your own name but a corporation holds the registration, the corporation's number may not match. Check whose name is on the account first; for costs you paid personally, see business expenses paid personally.
To check a supplier, use the CRA's GST/HST Registry, entering the first nine digits only. Non-resident digital businesses registered under the simplified system are on a separate CRA list with legal name, trade names, business number and effective dates. The check matters because a credit should cover only tax charged by a registered supplier (CRA: input tax credits).
The CRA's definitions page does not say what counts as satisfactory evidence of registration (CRA: definitions). Enter the number wherever the platform's billing or tax settings ask for it, and keep a dated screenshot or confirmation. Do not give a business number to avoid tax on a purchase you make as a consumer for personal use; s. 211.2 of the Act prohibits it.
The platform already charged me: can I claim the tax as an input tax credit?
It depends on who billed you. If the supplier is a non-resident on the simplified list, the CRA says a registered business that did not give evidence of registration is charged the tax and cannot claim it as an input tax credit or rebate (CRA). If the supplier is registered the ordinary way, including a Canadian entity, the usual input tax credit rules apply. A business on the Quick Method cannot claim a separate credit for operating expenses such as ads (CRA: input tax credits); see filing GST/HST and claiming credits.
An ordinary credit needs ads used to make taxable sales (your commercial activities), an invoice with the details the CRA lists, and a claim inside the time limit (four years for most registrants; CRA: input tax credits). For invoice details, see what a receipt must show. For the return itself, see filing GST/HST and claiming credits.
If a filed return already claimed a credit on tax from a simplified-list supplier, see correcting a filed GST/HST return. If the CRA is reviewing your credits, see GST/HST reviews and audits.
I gave my number and was still charged: who refunds it?
The platform does, not the CRA. The CRA says a registered customer that gave its number and was charged anyway can ask the supplier for a refund (CRA: cross-border digital products and services). The Act lets a supplier refund or credit tax charged in excess of what was collectible, within 2 years of the day it was charged or collected. The supplier then issues a credit note unless you issue a debit note (Act, s. 232).
The Act says the supplier "may" do this. It does not force the platform to refund. Ask in writing, and give the invoice number, the tax charged, the date the platform recorded your number and the date it charged the tax.
If you were registered when the supply was made but gave your number later, CRA Notice 322 says you may ask the platform for a refund or credit, showing that your registration was already in effect. The platform must agree and act inside its time limit. This is not an input tax credit or GST189 claim, which stay barred. When the supply, the invoice and the date your number was recorded differ, have those invoices read before the time limit passes.
Is the paid-in-error rebate (form GST189) an option?
Not for tax a platform on the simplified list collected from a registered business. The CRA says that tax is not recoverable by input tax credit or by a paid-in-error rebate application (CRA). The Act says the same: s. 211.17 bars any input tax credit, rebate, refund or remission tied to tax collected by a simplified-system registrant. Its exceptions include the supplier's own refund or credit under s. 232, certain rebates for charities and qualifying non-profit organizations (s. 259), and a paid-in-error rebate for tax collected from a buyer that was not registered the ordinary way at the time. That last rebate still needs an amount that was not payable (Act, s. 261).
Form GST189 under reason code 1C is for tax paid in error to other suppliers, such as one registered the ordinary way that charged tax it should not have. The CRA's rebate guide says to ask the supplier for a refund or credit first. If the supplier will not, apply within 2 years after paying (CRA: RC4033). The deadline runs from the day each amount was paid, so each month's charge has its own clock.
What if I am not registered, a small supplier, or only make exempt supplies?
Without a registration number there is nothing to give. Registering is the only way to get one.
Not registered. For most businesses, taxable sales at or below $30,000 over four consecutive calendar quarters, and in any single quarter, make a small supplier who does not have to register. The test counts worldwide taxable sales, including zero-rated sales and those of associates; a sole proprietor combines all their businesses. It may register voluntarily if it makes taxable supplies in Canada (CRA: when to register). A voluntary registration usually takes effect on the day you request it, or up to 30 days earlier. An earlier date needs a written request, and the CRA allows one where registration was already required or the business had acted as a registrant (CRA: backdating). Registration does not by itself undo tax already charged. Registering brings other duties; weigh them first using when to register for GST/HST.
Only exempt supplies. The CRA says a business that provides only exempt supplies generally cannot register (CRA). It has no number to give, and the tax is generally a cost. A charity or qualifying non-profit organization may have a rebate under s. 259.
Both taxable and exempt supplies. You can register and give your number, but the ads may serve your exempt activities too. Giving your number may stop the platform's charge, yet you may still have to self-assess GST/HST on imported services not used exclusively in commercial activities (Act, s. 217). That test is in invoices from foreign suppliers and contractors; the credit split is in clinics with exempt and taxable sales.
I buy ads for clients or rebill ad spend: what changes?
The tax follows the platform's customer, so the number that matters is the customer's. If an agency opens the ad account in its own name and bills clients, the agency is the platform's customer. Its registration number avoids the charge, and the GST/HST on what it bills clients follows rebilled expenses and disbursements.
If the agency acts as its client's agent, the client is the recipient of the platform's supply, so the client's number is the one to give. That applies the CRA's rule for a supplier's out-of-pocket expenses (GI-197) to ad accounts by analogy, and the CRA says whether a supplier acts as its client's agent is a question of fact and law (same page). An agency that is not registered has no number to give in its own name.
How far back can I fix past invoices, and what do I keep?
Each route has its own clock, and each invoice runs separately.
| Route | Time limit | Runs from |
|---|---|---|
| Platform refund or credit of tax charged in excess (the platform's window to act; ask well before it closes) | 2 years | The day the tax was charged or collected (Act, s. 232) |
| Paid-in-error rebate, form GST189 (not for simplified-list tax charged to a registrant) | 2 years | The day the amount was paid (Act, s. 261) |
| Ordinary input tax credit | four years | Counted by reporting period, as the CRA explains |
| Keeping records | 6 years | The end of the year the records relate to (CRA: records to keep) |
Keep every invoice that shows the billing entity and the tax, the bank or card statements, proof of the date you gave the platform your number, each refund request and reply, and any credit note.
How do I record ad invoices that show tax?
Record the ad cost and the tax on separate lines, then treat the tax by what you can recover.
- Tax you can claim as an input tax credit (not on the Quick Method): keep it out of advertising expense, in your GST/HST account, and claim it on the return. The CRA's guide for sole proprietors says deductible expenses include the GST/HST incurred less any input tax credit claimed (CRA: T4002).
- Tax you cannot claim: leave it in the advertising expense.
- A platform refund or credit note: reverse it against the expense line the tax was booked to.
- A GST189 rebate: the same guide says to subtract a rebate from the expense it applies to.
The source above covers sole proprietors; a corporation or partnership should have its preparer confirm how the amounts reach the return.
Example
These examples are illustrative; all amounts are in Canadian dollars.
A registered business gives its number part-way through the year
An Ontario business registered for GST/HST spends C$10,000 a month on ads and is charged C$1,300 of HST a month (13%) by a non-resident platform on the simplified list. On April 1 it enters its registration number in the platform account.
- The January to March invoices carried C$3,900 of tax in total. If the business was registered throughout those months, CRA Notice 322 says it may ask the platform for a refund or credit by showing its registration was in effect when each supply was made. The platform must agree and act inside its time limit. It is not a credit on the return.
- From April the invoices should show no tax. If the May invoice still shows C$1,300, that is tax charged after the number was given: a refund request to the platform inside its time limit, not a credit on the return.
A freelancer who is not registered
A designer in Ontario with C$20,000 of yearly taxable sales pays C$500 a month for ads and is charged C$65 of HST a month. With no registration number, there is nothing to give, so the charge continues until the designer registers. If the designer's taxable sales stay under the small-supplier limit, registration is optional. Registering is a choice to weigh against its duties, and it does not fix past invoices.
A clinic with only exempt supplies
A clinic that makes only exempt supplies generally cannot register, so it has no number to give. The HST on its ad invoices generally stays an advertising cost, with no input tax credit.
Different for you?
- Your ad invoices show tax and you never gave a platform your number, you gave it and were still charged, the ad account is not in the name of the business that holds the number, or the tax adds up: which invoices can still be corrected or refunded, whether your registration status changes the answer, and how the amounts sit in your returns and books depend on dates and the billing entity. The time limits above keep running, so see bookkeeping help for a professional read of the invoices.
- You already claimed credits on platform tax: see correcting a filed GST/HST return, and GST/HST reviews and audits if the CRA has written.
- You rebill ad spend to clients: follow rebilled expenses and disbursements.
- You are weighing registration: read when to register for GST/HST.
- Other foreign suppliers charge you tax: see invoices from foreign suppliers and contractors. For GST paid at the border, see GST on imports and customs invoices.
- Your books are behind: see catching up on overdue books and bookkeeping help.
Figures on this page
| Figure | Value | Source |
|---|---|---|
| Supplier window to adjust, refund, or credit excess GST/HST Measured from the day the excess was charged or collected under Excise Tax Act subsection 232(1). | 2 years | Justice Laws: Excise Tax Act, section 232 Checked |
| Usual GST/HST input tax credit claim window For a person who is not a specified person, measured from the end of the original reporting period; claim by the due date for the last reporting period ending in that window, subject to statutory exceptions | Four years | Justice Laws: Excise Tax Act, section 225(4)(b) Checked |
| Tax-paid-in-error rebate application window Measured from the day the claimant paid or remitted the amount under Excise Tax Act subsection 261(3). | 2 years | Justice Laws: Excise Tax Act, section 261 Checked |
| GST/HST small supplier threshold Worldwide taxable sales, including zero-rated supplies, with associates, in one calendar quarter or over the last four consecutive calendar quarters; excludes financial services, sales of capital property and goodwill | $30,000 | CRA: When to register for and start charging the GST/HST Checked |
| Earliest accepted voluntary GST/HST registration effective date before application CRA accepts an earlier effective date within 30 days of receiving a voluntary registration application | 30 days | CRA: General Information for GST/HST Registrants Checked |
| Usual GST/HST records retention period Generally from the end of the last tax year to which the records relate; long-term property records and other exceptions can require longer retention | 6 years | CRA: GST/HST records to keep Checked |
Primary sources
- CRA: Cross-border digital products and services
- CRA: Confirming a simplified GST/HST account number
- CRA: Definitions under the digital economy measures
- CRA: GST/HST Notice 322, Recovery of the GST/HST under the digital economy measures
- CRA: Input tax credits
- CRA: General Application for GST/HST Rebates (RC4033)
- CRA: When to register for and start charging the GST/HST
- CRA: Request a GST/HST registration to be backdated by more than 30 days
- Justice Laws: Excise Tax Act, section 211.2
- Justice Laws: Excise Tax Act, section 217
- CRA: General Information for GST/HST Registrants (RC4022)
- CRA: Confirming a GST/HST account number
- CRA: GST/HST on imports and exports
- CRA: GST/HST Info Sheet GI-197, Out-of-pocket expenses
- CRA: GST/HST records to keep
- CRA: T4002, Chapter 3, Expenses
- Justice Laws: Excise Tax Act, section 211.1
- Justice Laws: Excise Tax Act, section 211.17
- Justice Laws: Excise Tax Act, section 232
- Justice Laws: Excise Tax Act, section 259
- Justice Laws: Excise Tax Act, section 261
About this guide
Published by Cloud Accounting under standing professional approval. This version has no separately recorded personal review. It explains general rules for the tax year shown. It is not advice for your situation.
Changes
- : First published.