We are often asked about “accommodation invoices”, and what the CRA is talking about when speaking about these types of invoices.
This is predominantly a term that is used in the GST context but is not defined anywhere in the Excise Tax Act (i.e., the GST legislation) or relatively speaking anywhere in any published CRA administrative document.
But CRA does disclose what it means by “Accommodation Invoices” when it comes time to assess wary taxpayers:
Accommodation Invoices
An accommodation invoice is one that is issued either where no goods or services are provided, or to change the nature of the goods or services that are provided. The registered supplier may not be aware that these invoices are prepared, as they may be prepared by the recipient of the purported supply. These suppliers are usually complicit in the scheme, either through active participation in or willful blindness to the transactions and flow of funds.
What this basically means is that when the CRA is talking about “Accommodation Invoices” it is usually considering a sham or carousel scheme assessment – or worse, perhaps a criminal investigation – and legal advice is probably called for immediately.
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