The CRA has a mandate to improve compliance of GST/HST registrants and to encourage GST/HST registrants to meet their filing requirements.  As part of its commitment to this mandate, the CRA will be implementing changes to its current processes.


Currently, the CRA may place a non-compliance hold on a person’s accounts, if the person is a non-compliant GST/HST registrant.  A non-compliance hold prevents any refunds or credits from being issued to the registrant, until the registrant is compliant.


In Excise and GST/HST News No. 100, the CRA announced that in May of 2017 they will be putting refund/credit holds on all non-compliant GST/HST accounts – including accounts of financial institutions who have outstanding GST 111 Annual Information Returns


This is an expansion of the CRA’s current procedure of placing holds on non-compliant accounts to prevent the issuance of refunds/credits until the account is brought into compliance.  


Practitioners who have clients who are financial institutions should make sure their clients are aware of their filing requirements.  Don’t forget about de minimis financial institutions!


John G. Bassindale

Millar Kreklewetz LLP