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Published | Category : GST and QST

Harmonization With the Proposed E-Commerce Measures Announced in the Federal Budget of April 19, 2021

As part of the federal budget delivered on April 19, 2021, the federal Minister of Finance tabled a Notice of Ways and Means to amend the Excise Tax Act and adjust the federal proposals made on November 30, 2020, concerning the application of the goods and services tax (GST) and harmonized sales tax (HST) to e-commerce supplies.

As the Québec sales tax (QST) system is generally harmonized with the GST/HST system, the new e-commerce rules will be incorporated into the QST system, taking into account the particularities of the QST and the provincial context in which it operates.

For more information, see An Act to amend the Taxation Act, the Act respecting the Québec sales tax and other provisions.

Application date

The new measures come into effect on July 1, 2021.

Although the proposed amendments require parliamentary assent, Revenu Québec will administer them in accordance with the federal bill and Québec legislation, as per its usual practices.

Simplified QST registration

The general QST registration process is more complex than the specified registration process for suppliers outside Québec. Because of the harmonization of the QST system with the federal proposals made on November 30, 2020, some non-resident businesses and platform operators will have to register under the general QST system rather than the specified registration system.

To make it easier for suppliers subject to the new obligations to register under the general QST system, a simplified registration process will be offered. Suppliers that are registered under the general GST/HST system will not have to provide prescribed information again.

After providing their GST/HST number, suppliers will be relieved of their obligation to provide certain prescribed information already provided to the Canada Revenue Agency and will then be able to register with Revenu Québec by providing minimal information. This will simplify the process of registering under the general QST system while giving Revenu Québec the assurance that it has all the information it needs to proceed with the registration.

More details on the simplified registration process will follow shortly.

Administration and compliance

Similar to the model announced in the 2018-2019 budget speech, where the specified registration system was introduced, Revenu Québec will once again adopt a practical approach to compliance for businesses and platform operators affected by the new e-commerce provisions.

Revenu Québec will work closely with businesses and platform operators for 12 months after the new provisions come into effect to help them meet their obligations. If they demonstrate that they have taken reasonable measures but are unable to comply with their new obligations for operational reasons, Revenu Québec will provide assistance and exercise its discretion in administering the measures.

After the 12-month period, the penalties provided for in existing tax legislation will be applied to businesses and platform operators that do not comply with the new obligations.

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