The recurring theme of this series has been that the decisive record is usually held by someone else. A municipality holds the permit. A platform holds the bookings. A lender holds the loan. Until recently CRA had to go and get those records. For one large category it no longer does.
Key Takeaway
Part XX of the Income Tax Act, enacted by Bill C-47 which received Royal Assent on 22 June 2023, implements the OECD Model Rules for Reporting by Platform Operators. It took effect on 1 January 2024, with the first information return due 31 January 2025 for the 2024 calendar year. Reporting platform operators must collect and verify seller information and report it annually, and must send the same information to each reportable seller by the same date. The de minimis exclusion reported by commentary covers fewer than 30 activities for the sale of goods with consideration not exceeding $2,800, and both conditions must hold. Consideration is reported by quarter along with the number of activities. Canada did not adopt the OECD's optional exclusion for platforms below a stated annual threshold.
A Note On Currency
Everything here is stated as verified in August 2026 and requires confirmation before reliance. This is a new regime and both the legislation and CRA's guidance have been supplemented since enactment.
We have not read Part XX or CRA's guidance document. Every description here comes from professional commentary and from a CRA technical interpretation, and section references are as those sources cite them.
Amounts, thresholds and penalty figures are reported from commentary and should be confirmed. The list of partner jurisdictions changes and must be taken from CRA's own published list.
This is not tax advice. Platform operators face registration and filing obligations with penalties attached, and sellers face a change in what CRA can see about their income; both should take advice on their own position.
What Changed
The legislation and its dates.
Commentary records that on 22 June 2023 Bill C-47, Budget Implementation Act, 2023, No. 1, received Royal Assent, enacting Part XX of the Income Tax Act, Reporting Rules for Digital Platform Operators, implementing the model rules developed by the OECD[1][2].
A CRA technical interpretation states that the rules took effect on 1 January 2024, with the first reporting due on 31 January 2025 in respect of the 2024 calendar year[3].
Commentary describes the obligation: platform operators have to collect detailed information on sellers, the information needs to be verified, and it must be reported to CRA annually[3]. Another describes it as requiring operators to collect names, addresses, tax identification numbers and transaction data, perform due diligence, and file annual information returns[4].
Two features of that are worth isolating and this is our own emphasis.
The reporting is automatic and recurring. It does not depend on CRA identifying a taxpayer, forming a suspicion, or issuing a demand. It happens every January for every reportable seller.
And it is verified. The operator is not merely passing along whatever a seller typed into a signup form; it has due diligence obligations addressed later in this article.
Interpreted Consistently With The Model
An interpretive rule with real consequences.
A CRA technical interpretation states that under subsection 282(2), the provisions in Part XX must be interpreted consistently with the OECD Model Rules, as amended from time to time, unless the context requires otherwise[3]. Commentary states the same rule[2].
Three things follow, and they are ours.
The Canadian text is not self-contained. A question about Part XX may be answered by reference to an international instrument, which means the relevant material is not entirely domestic.
The phrase as amended from time to time is unusual and consequential. It ties Canadian interpretation to a document that can change without Canadian legislation changing.
And it explains why guidance and commentary in this area draw on OECD sources. An operator with a genuine interpretive question is looking at a body of material broader than the Act.
For a Canadian business the practical implication is narrow but useful: an interpretation of the equivalent rules in another adopting jurisdiction may be informative in a way that is unusual in tax, because both are implementing the same model.
What Counts As A Platform
The definition, which is wider than the obvious candidates.
Commentary states that for Part XX purposes a platform is any software, including all or part of a website and applications, including mobile applications, that is accessible by users and allows sellers to connect with other users for the provision of relevant services or the sale of goods[2].
And a platform operator is described as any entity that contracts with sellers to make a platform available to sellers[1].
Read those together and the reach is considerable, which is our own analysis.
The household names are obviously caught: ride-hailing, food delivery, accommodation rental, freelance marketplaces, online retail marketplaces.
Less obviously, the definition refers to all or part of a website. A business whose primary activity is something else, but part of whose site allows third parties to sell to its users, is describable in those terms.
Industry associations with member directories that permit booking. Property managers operating a booking portal for owners. Trade bodies running marketplaces. Franchise systems with a customer-facing ordering platform used by independently owned outlets.
We are not asserting that any of those is a reporting platform operator; that depends on the definitions and on facts we have not examined. The point is narrower: a business that has never thought of itself as a platform should establish its position rather than assume the rules are aimed elsewhere.
Who Has To Report
The obligated population.
Commentary states that in general, platform operators are reporting platform operators, and thereby subject to Part XX due diligence and reporting requirements, if they are resident in Canada[1].
Residence is therefore the primary trigger, which makes the obligation straightforward to identify for a Canadian business.
Note what is not in that test, which is our own observation.
There is no reference to size, to revenue, to the number of sellers, or to whether the platform is the business's main activity. A Canadian entity that contracts with sellers to make a platform available to them is within the description.
That is a meaningfully different structure from most reporting obligations in Canadian tax, which typically attach above a threshold or to a defined industry.
The next two sections address the two ways the population is wider still: non-residents, and the absence of a small-platform exclusion.
The Non-Resident Reach
How the rules capture platforms outside Canada.
Commentary states that a reporting platform operator also includes a non-resident platform operator that facilitates the provision of relevant activities by sellers resident in Canada, or with respect to renting immovable property in Canada[1].
It adds that a non-resident operator may elect to be a reporting platform operator if it is resident, incorporated or managed in a partner jurisdiction[1].
Two observations, ours.
The first limb is the practically significant one for Canadian sellers. A foreign platform with Canadian sellers, or facilitating Canadian property rentals, is within the reporting population.
That means a Canadian seller does not escape reporting by using a platform based abroad, which is worth stating plainly because the opposite assumption is intuitive.
The election mechanism reflects the international architecture of the regime. Where a platform is in a partner jurisdiction, information can flow between administrations rather than requiring separate reporting, which is the point of building on an OECD model rather than a purely domestic rule.
For a Canadian operator with foreign sellers, the same architecture works in the other direction, and the partner jurisdiction list becomes relevant to its own obligations.
No Exclusion For Small Platforms
A deliberate Canadian divergence from the model, and it matters.
Commentary notes specifically that in the Canadian rules there was no exclusion for platform operators that facilitated the provision of relevant activities for which the total consideration over the previous year was less than one million euros and that elected to be excluded from reporting[2].
That is a reference to an optional carve-out in the model that Canada did not take up, and this is our own analysis of its effect.
A small Canadian platform, facilitating a modest volume of activity, has the same registration, due diligence and reporting obligations as an international marketplace.
The compliance cost of those obligations does not scale down with the platform. Collecting and verifying tax identification numbers, maintaining due diligence records, registering with CRA and filing a structured information return are fixed exercises.
So the burden is proportionally heaviest on exactly the smallest operators, who are also the least likely to know the rules exist.
The population we would be most concerned about is not the well-advised technology company. It is the small Canadian business that built a booking or marketplace function into its website for commercial reasons and has never considered that this might make it a reporting entity.
The Four Activities
What triggers reporting for a seller.
Commentary identifies the relevant activities as covering the provision of relevant services, the sale of goods, the rental of immovable property, and the rental of means of transportation[5][1].
Reportable sellers are described as active sellers, being those that provide relevant services or sell goods, or that have received consideration for such activities during a reportable period[1].
Mapped onto real Canadian activity, and these are our own examples, the four categories cover most of what people mean by the gig and sharing economy.
Services: ride-hailing, delivery, freelance and professional work through marketplaces, home services, tutoring, personal care.
Goods: online marketplace selling, resale platforms, handmade and craft marketplaces.
Immovable property: short-term accommodation rental, parking and storage space, event and workspace rental.
Means of transportation: peer-to-peer car rental, boat and recreational vehicle rental.
The third category connects directly to an earlier article in this series. A short-term rental operator is a reportable seller here, and separately faces the deduction denial tied to municipal compliance. The platform's report establishes the rental activity; the municipality's register establishes the licence.
The Threshold, And What It Covers
The exclusion, and the limit on it that most summaries omit.
Commentary describes the excluded persons as those for whom the platform operator facilitated less than 30 relevant activities for the sale of goods and for which the total consideration did not exceed $2,800 in the reportable period[5].
Read that carefully, because two features determine its practical scope and this is our own emphasis.
The exclusion is expressed by reference to activities for the sale of goods. On that reading it does not extend to the other three categories of relevant activity.
And it contains two conditions joined by "and". A seller must be under the activity count and under the consideration figure. Failing either removes the exclusion.
We report the $2,800 figure as commentary states it, note that it appears to be a Canadian dollar equivalent of a euro amount in the model rules, and recommend confirming both the figure and its application for the period concerned.
The next two sections work through what those two features mean in practice, because in our view they are the most misunderstood part of this regime.
Thirty Sales Of Five Hundred Dollars
The interaction of the two conditions, worked through. These are our own calculations applying the reported thresholds.
Twelve sales totalling $1,800 is excluded. Both conditions hold.
Twenty-nine sales totalling $2,800 is excluded, being just inside both.
Twenty-nine sales totalling $2,801 is reportable, on consideration.
Thirty sales totalling $500 is reportable, on activity count, despite the amount being trivial.
Five sales totalling $4,000 is reportable, on consideration, despite the volume being trivial.
The fourth of those is the one worth dwelling on.
A person clearing out a garage over a year, selling thirty items on a marketplace for an average of under seventeen dollars each, is a reportable seller.
Whether they have taxable income is an entirely separate question, and in most such cases they will not. Personal-use property sold at a loss is not income, and this article does not suggest otherwise.
But their name, address, tax identification number and quarterly consideration figures go to CRA, and a copy comes to them.
That distinction, between being reported and owing tax, is the single thing most likely to cause unnecessary alarm as these reports reach households, and it is worth stating clearly in both directions.
For Services And Rentals, No Threshold At All
The more consequential of the two features. This section is our own analysis of the reported rule.
On the description above, the de minimis exclusion applies to activities for the sale of goods. It is not described as applying to relevant services, to rentals of immovable property, or to rentals of means of transportation.
If that reading is right, and an operator should confirm it, the consequence is that a seller in those three categories is reportable without any minimum.
A person who drove for a ride-hailing platform on four evenings. Someone who rented a spare room for a single weekend. A freelancer who took one small assignment through a marketplace.
Each is an active seller who received consideration for a relevant activity, and no threshold appears to stand between them and a report.
That asymmetry has a defensible logic. Selling used household items is frequently not a commercial activity, whereas providing a service or renting property for consideration usually is.
But it produces a practical result worth understanding: the categories with no threshold are precisely the ones where casual participation is most common.
The number of Canadians who have done a small amount of platform work, or rented something once, is very large, and on this reading essentially all of them are now reported.
Reported By Quarter
The granularity of what is reported, which is finer than an annual figure.
Commentary states that where the seller provides relevant services, sells goods or rents out means of transportation, the operator reports the total consideration paid by quarter and the number of relevant activities in respect of which it was paid[5].
On our own count, that is eight data points per seller per year for those categories: four consideration figures and four activity counts.
Three consequences follow, all ours.
CRA receives a pattern, not a total. Seasonality, growth, a mid-year start and a mid-year stop are all visible on the face of the report.
The activity count is independently useful. Consideration divided by activities gives an average transaction value, which can be compared against sector norms in the way this series described in the indirect verification article.
And a seller's own return can be compared against the report at a level of detail that makes a discrepancy hard to explain vaguely. It is one thing to account for an annual difference; it is another to explain why three quarters match and one does not.
For a seller who maintains proper records this is unremarkable. For one who has been estimating, it is a meaningful change.
The Seller Gets A Copy
The provision we consider most important in this article for the largest number of people.
Commentary states that a reporting platform operator is required to report to each reportable seller the data that has been reported to CRA, by the same date[5]. Another states that the reported information also needs to be submitted to the related reportable seller on or before the same date[6].
So the seller is not in the dark. They receive the same figures the Agency receives, at the same time.
That is a genuinely unusual feature of a third-party reporting regime, and this is our own analysis of why it matters so much.
Every other third-party record described in this series was invisible to the taxpayer. The construction subcontractor could not see the aggregate of slips filed about them. The short-term rental operator could not see the municipal register. The taxpayer under net worth analysis could not see what the auditor had assembled.
Here the information is disclosed to the person it concerns, before they file.
The practical instruction that follows is simple and, in our view, the most valuable thing in this article: use it.
What That Actually Means
How a seller should treat the statement they receive. This section is our own analysis.
The copy arrives by the end of January, in respect of the calendar year just ended, and before a personal return is due. That timing is not accidental and it is useful.
Four things a seller should do with it.
Reconcile it against their own records. If the two do not agree, the difference should be understood before filing rather than explained afterwards.
Understand what the figure represents. Consideration reported by a platform is typically gross. It will not be net of the platform's fees, of costs, or of amounts refunded, and a seller who reports the gross figure as profit has overstated their income.
Check for amounts that are not income. Refunded transactions, amounts collected on behalf of others, and taxes collected may all sit inside a gross consideration figure depending on the platform.
Keep it. It is the document that will be compared against the return, and having it on file with a reconciliation is the difference between answering a query in an afternoon and reconstructing a year.
The corresponding warning is the mirror image. A seller who receives a statement showing figures materially above what they reported, and does nothing, has been told in advance exactly what the discrepancy is.
This series has described a route for dealing with a historical position, and its terms depend on who moves first. A statement in hand and an unfiled correction is precisely the situation in which that distinction is worth money.
Due Diligence On Sellers
The operator's verification obligations, which go beyond collecting a form.
Commentary states that reporting platform operators are required to follow legislated due diligence procedures, which include the use of all available records, as well as any publicly available electronic interface to verify the validity of a seller's tax identification number[5].
Two features of that, ours.
The reference to all available records means the operator cannot confine itself to the signup form. Information it holds elsewhere about a seller is within scope.
And the requirement to use a publicly available verification interface where one exists means the operator is expected to check a number rather than record it. That is an active obligation.
For an operator this is a systems question rather than a policy one. Verification at scale has to be built into onboarding, and retrofitting it across an existing seller base is materially harder than designing it in.
For a seller, the practical consequence is that a wrong or missing tax identification number will be pursued. An operator with a filing obligation and penalties attached has every reason to chase sellers whose details do not verify, and sellers should expect that contact rather than treat it as optional.
The Tax Identification Number
What is being collected, and a reasonable limit on the obligation.
Commentary states that the Act defines a tax identification number as a number used by the minister to identify an individual or entity, such as a social insurance number, business number or an account number issued to a trust. For a jurisdiction other than Canada, it is a taxpayer identification number, including a VAT or GST registration number issued by the jurisdiction of the seller's primary address[2].
It adds that no penalty applies if the reportable seller cannot obtain a number from the relevant reporting jurisdiction, for example where the jurisdiction does not issue them[2].
Three points, ours.
For a Canadian individual seller the number collected will typically be a social insurance number, which is a meaningful escalation in the sensitivity of what platforms hold and a reason for sellers to be attentive to how it is requested.
That also creates a fraud risk worth naming. Sellers should expect legitimate requests from platforms they actually use, and should treat unsolicited approaches purporting to require a social insurance number for tax reporting with the caution such requests always deserve.
And the relief where a jurisdiction does not issue numbers is a sensible limit, but it is narrow. It addresses an impossibility, not an inconvenience, and a seller who simply has not provided a number is not within it.
Penalties And The Relief Window
The consequences of not filing, and a concession that has now passed.
Commentary states that penalties under subsection 162(7.01) apply to a reporting platform operator who fails to file one or more information returns in accordance with Part XX[2]. Another reports that late filing may result in penalties ranging from $100 to $7,500[6].
On the concession, a CRA technical interpretation records that as a matter of administrative relief, CRA would waive penalties and interest on late-filed information returns originally due on 31 January 2025, provided those returns were submitted no later than 31 July 2025[3][6].
Two observations, ours.
That relief window has closed. An operator that has still not filed for 2024 is outside it, and the penalty provision applies on its own terms.
More importantly, an operator that has never filed at all is not merely late for one year. Obligations have continued to accrue for each subsequent year, and an operator discovering the regime now has more than one return outstanding.
The penalty provision cited is the same one this series encountered in the construction article, where the applicable figure was not straightforward and two different penalty structures were in play. An operator should establish which computation applies rather than rely on a reported range.
The Anti-Avoidance Rule
A provision addressing structuring around the obligation.
Commentary refers to a rule applying to a person who enters into an arrangement or engages in a practice primarily to avoid an obligation under these rules[2].
We did not obtain the full provision or its consequences, and report only that it exists.
Its presence is nonetheless informative, and this is our own analysis.
Reporting regimes of this kind invite structural responses: splitting a platform, routing transactions through an entity outside the definition, restructuring the contractual relationship with sellers so that the operator does not contract with them, or fragmenting seller accounts so that each falls below a threshold.
A rule directed at arrangements entered into primarily to avoid the obligation exists because the drafters anticipated exactly that.
The practical point for an operator considering a restructuring for commercial reasons is that the reporting consequence should be assessed as part of the decision, and the reasons for the change should be documented as they are made.
A commercially driven change that happens to reduce a reporting obligation is a different thing from a change made for that purpose, and the evidence distinguishing them is contemporaneous.
Registration Mechanics
The administrative steps, which take time.
Commentary states that before filing a Part XX information return for the first time, reporting platform operators must obtain a business number and register for an information returns RZ program account with CRA[7].
It also records that CRA released guidance on the rules on 5 September 2024, providing details on how to complete the return[7].
Two practical points, ours.
Registration is a prerequisite rather than a formality. An operator that identifies its obligation shortly before a deadline may not be able to file on time simply because the account is not yet in place.
This is the same structural pattern this series has now identified three times: an administrative registration that gates the substantive act. The cannabis licensee could not obtain stamps with an outstanding return. The flow-through issuer could not renounce without an identification number. Here an operator cannot file without an account.
In each case the failure is procedural and the consequence is substantive, and in each case the remedy is to deal with the registration well before it is needed.
Partner Jurisdictions
A moving list that affects who reports what.
Commentary records that as at its publication date three countries were listed on CRA's website as partner jurisdictions for Part XX purposes, and that additional countries were expected to be listed[7]. Another refers readers to CRA's published list of partner jurisdictions and the relevant effective date of each partnership[6].
Three points, ours.
The list is small and growing, so any statement about it dates quickly. An operator must take it from CRA's own page rather than from commentary, including this article.
Each partnership has an effective date, which means the position for a given reportable period depends on when a jurisdiction joined rather than on its current status.
And the direction of travel matters for planning. As the list grows, the scope for information to flow between administrations grows with it, which affects operators with foreign sellers and Canadian sellers on foreign platforms alike.
What This Means Across This Series
The connection, since this article completes a theme. This section is our own analysis.
The first article in this series described CRA obtaining municipal building permits and matching them against its own registrations. Later articles described unnamed persons requirements, licensing registers, information slips, insurer records and lender documentation.
In every case the pattern was the same: the record that establishes a taxpayer's position is held by a third party, created for reasons unconnected with tax.
What changed on 1 January 2024 is that for one large category the Agency no longer has to go and find it. The record is compiled to a specification, verified, and delivered annually.
Two implications follow for the businesses this series is written for.
The margin for estimation has narrowed considerably in platform-mediated activity. A seller whose reported income does not match a quarterly statement filed about them is in a different position from one whose records were merely incomplete.
And the direction of travel is clear. A regime built on an international model, tied to that model as amended from time to time, with a growing list of partner jurisdictions, is not a one-off measure.
The reasonable planning assumption for any business is that third-party visibility of its revenue increases rather than decreases, and that positions which depend on nobody looking have a limited life.
If You Are A Seller
A short section for the far larger population, offered as our own.
Expect a statement in January. Operators must send you the same information they send CRA, by the same date.
Do not assume a small amount means no report. On the reported thresholds, thirty sales of goods totalling $500 is reportable, and for services and rentals no threshold appears to apply at all.
Being reported is not the same as owing tax. A report establishes that consideration was received; whether it produced taxable income is a separate question, and selling personal items at a loss generally does not.
Reconcile before you file, not after. The statement arrives before your return is due, which is the whole point of the timing.
Remember the figure is likely gross. Platform fees, costs and refunds sit inside it, and reporting the gross number as income overstates it.
Provide your number when a platform you use asks. The operator has a filing obligation with penalties attached and will pursue it, and an unverified account creates friction you do not need.
If the statement shows more than you reported for earlier years, take advice promptly. The route available for correcting a historical position depends on who moves first.
What To Do
Establish whether you are a platform operator at all. The definition covers all or part of a website that allows sellers to connect with users, and residence is the primary trigger with no size threshold.
Do not rely on being small. Canada did not adopt the model's optional exclusion for platforms below a stated annual threshold.
Register for the account before you need it. A business number and an information returns program account are prerequisites to filing.
Check whether you have missed years. The regime began with the 2024 calendar year, and the relief window that ran to 31 July 2025 has closed.
Build verification into onboarding. Due diligence includes using publicly available interfaces to verify a seller's tax identification number, which is a systems requirement rather than a policy.
Apply the de minimis correctly. On the reported rule it covers sale of goods only, and both the activity count and the consideration condition must hold.
Send sellers their statements on time. The obligation to report to each reportable seller runs to the same date as the filing.
Take the partner jurisdiction list from CRA, not from commentary. It is small, growing, and each partnership has its own effective date.
Document the commercial reasons for any restructuring. An anti-avoidance rule addresses arrangements entered into primarily to avoid the obligation.
The Limits Of This Analysis
Several caveats matter. This is not tax advice; operators face registration and filing obligations with penalties attached, and sellers face a change in visibility, and both should take advice on their own position. Everything is stated as verified in August 2026 and requires confirmation; this is a new regime and both the legislation and CRA's guidance have been supplemented since enactment. We have not read Part XX, the OECD Model Rules, or CRA's guidance document, and every description here comes from professional commentary and a CRA technical interpretation, with section references as those sources cite them. The de minimis figures, the penalty range, the reporting content and the due diligence description are reported from commentary and must be confirmed; our reading that the de minimis applies only to the sale of goods follows from how commentary describes it and should be verified against the legislation before being relied on. We did not obtain the text or consequences of the anti-avoidance provision. The number of partner jurisdictions reported reflects one commentator's publication date and the list must be taken from CRA's own page. We have not addressed the interaction between Part XX reporting and GST/HST obligations, nor the position of sellers who are not resident in Canada. All arithmetic is our own, applies the reported thresholds to hypothetical fact patterns, and is illustrative only. The platform-definition observations, the analysis of the burden falling hardest on small operators, the reconciliation guidance for sellers, the connection drawn to other articles in this series and the registration-as-gate observation are our own. This article does not address employment status of platform workers, provincial obligations, or the separate reporting regimes applying to financial accounts.
Frequently Asked Questions
What is actually reported about me?
Is there a minimum before I get reported?
Does being reported mean I owe tax?
Will I see what was sent?
We run a small platform. Are we caught?
We have never filed. What now?
References
- EY Canada. Tax Alert 2024 No. 62: Digital Platform Operators — First Information Return Is Due by 31 January 2025, on Bill C-47, Budget Implementation Act, 2023, No. 1, having enacted Part XX of the Income Tax Act on 22 June 2023, implementing the OECD model rules for digital platform operators; on a platform operator including any entity that contracts with sellers to make a platform available to sellers; on platform operators generally being reporting platform operators subject to Part XX due diligence and reporting requirements if resident in Canada; on a reporting platform operator also including a non-resident platform operator that facilitates the provision of relevant activities by sellers resident in Canada or with respect to renting immovable property in Canada; on a non-resident operator being able to elect to be a reporting platform operator if resident, incorporated or managed in a partner jurisdiction; on reportable sellers being active sellers that provide relevant services or sell goods or have received consideration for such activities during a reportable period; on first information returns being due by 31 January 2025 in respect of the 2024 calendar year; and on a reporting platform operator being required to report identifying information for its own business including name, registered office address and tax identification number. Note: an accounting firm publication; we have not read the legislation. ey.com
- EY Global. Canada's New Reporting Rules for Digital Platform Operators Take Effect 1 January 2024, on Bill C-47 enacting Part XX and implementing draft legislative proposals released on 3 November 2022 subject to minor modifications; on the provisions in Part XX being required to be interpreted consistently with the OECD model rules unless the context requires otherwise; on a platform being any software, including all or part of a website and applications including mobile applications, accessible by users and allowing sellers to connect with other users for the provision of relevant services or the sale of goods; on there being no exclusion for platform operators facilitating relevant activities for which total consideration over the previous year was less than one million euros and that elected to be excluded from reporting; on the definition of a tax identification number as a number used by the minister to identify an individual or entity such as a social insurance number, business number or trust account number, and for other jurisdictions a taxpayer identification number including a VAT or GST registration number; on no penalty applying if the reportable seller cannot obtain a number from the relevant reporting jurisdiction; on penalties under subsection 162(7.01) applying to a reporting platform operator who fails to file; and on a rule addressing a person who enters into an arrangement or engages in a practice primarily to avoid an obligation. Note: an accounting firm publication; we did not obtain the text of the anti-avoidance provision. ey.com
- Canada Revenue Agency technical interpretation 2025-1050201E5 (30 May 2025), Part XX Reporting Obligations, as reproduced by a tax interpretations service, on platform operators having to collect detailed information on sellers which needs to be verified and reported to CRA annually; on the rules taking effect on 1 January 2024 with the first reporting due on 31 January 2025 in respect of the 2024 calendar year; on CRA waiving, as a matter of administrative relief, penalties and interest on late-filed information returns originally due on 31 January 2025 provided those returns were submitted no later than 31 July 2025; and on subsection 282(2) requiring the provisions in Part XX to be interpreted consistently with the OECD Model Rules, as amended from time to time, unless the context requires otherwise. Note: accessed through a secondary reproduction. taxinterpretations.com — 2025-1050201E5
- NYBACS. (2025, September). Canada — New Reporting Rules for Digital Platform Operators, on Parliament adding Reporting Rules for Digital Platform Operators to the Income Tax Act as Part XX when Bill C-47 received Royal Assent on 22 June 2023; and on the rules, based on OECD model reporting rules, requiring reporting platform operators to collect detailed seller information including names, addresses, tax identification numbers and transaction data, perform due diligence and file annual information returns, effective from 1 January 2024 with first reports relating to 2024 due in early 2025. Note: a commercial publication. nybacs.com
- BDO Canada. (2024, November). Updated Digital Operator Reporting Rules, on excluded persons being those for whom the platform operator facilitated less than 30 relevant activities for the sale of goods and for which the total consideration did not exceed $2,800 in the reportable period; on the reporting of total consideration paid by quarter and the number of relevant activities in respect of which it was paid, where the seller provides other relevant services, sells goods or rents out means of transportation; on reporting platform operators being required to follow legislated due diligence procedures including the use of all available records as well as any publicly available electronic interface to verify the validity of a seller's tax identification number; on the first reportable period being the 2024 calendar year, to be reported to CRA by 31 January 2025; and on a reporting platform operator being required to report to each reportable seller the data reported to CRA by the same date. Note: an accounting firm publication; the reading that the de minimis applies only to the sale of goods follows from how this source describes it and should be verified against the legislation. bdo.ca
- Andersen in Canada. (2025, April). New Reporting Requirements for Digital Platform Operator, on reporting platform operators having an obligation to file an information return containing required information relating to reportable sellers on or before 31 January of the year following the calendar year in which a seller is identified as reportable, with the same information submitted to the reportable seller by the same date; on the first reporting period being the 2024 calendar year with returns due no later than 31 January 2025; on CRA announcing that related late filing penalties and interest would be waived until 31 July 2025; on late filing potentially resulting in penalties for reporting platform operators ranging from $100 to $7,500; and on referring readers to CRA's list of partner jurisdictions and the relevant effective date of each partnership. Note: a professional services firm publication. ca.andersen.com
- PwC Canada. Tax Insights: Reporting Rules for Digital Platform Operators, on CRA having released guidance on the new reporting rules on 5 September 2024, most notably providing details on how to complete the Part XX information return; on the legislation having received Royal Assent on 22 June 2023 and being based on the OECD Model Rules for Reporting by Platform Operators with respect to Sellers in the Sharing and Gig Economy; on reporting platform operators being required to register with CRA and file the Part XX information return; on the requirement, before filing for the first time, to obtain a business number and register for an information returns RZ program account; on the first filing deadline being 31 January 2025 for the 2024 calendar year; and on three countries being listed on CRA's website as partner jurisdictions as at the date of publication, with additional countries expected. Note: an accounting firm publication; the partner jurisdiction count reflects that publication date and must be taken from CRA's own list. pwc.com
This article is provided for general informational purposes and is not tax advice. The authors have not read Part XX, the OECD Model Rules, or CRA's guidance document, and rely on professional commentary and a CRA technical interpretation. Thresholds, penalty figures and reporting content are reported from commentary and must be confirmed. The partner jurisdiction list changes and must be taken from CRA's own page. All arithmetic is the authors' own and is illustrative only.