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Client Communication:
Finance announced today a proposed two-month GST/HST relief on a limited list of specified supplies starting December 14, 2024. As noted in the Backgrounder, the proposed relief would apply from December 14, 2024 to February 15, 2025. Finance notes that the temporarily relief would also apply on qualifying goods imported during this same period. The list of qualifying goods is very detailed. Suppliers will have to carefully determine if their supplies qualify for the proposed temporary relief before adjusting their systems.
Suppliers affected by the proposed GST/HST relief include retailers, grocers, restaurants, Christmas tree growers, as well as importers of such qualifying goods.
The Backgrounder notes the temporary relief applies to both GST and HST. I assume the provinces of Ontario, New Brunswick, Nova Scotia and Newfoundland and Labrador will likely also release notes or comments about this temporary HST relief.
Based on the Backgrounder, this measure appears to simply be a GST/HST relief. At first glance, the temporary relief does not appear to amend the tax status of the qualifying goods, and as such, should not affect Suppliers’ ITC claims. There is no comment in the Backgrounder on measures related to qualifying goods recently purchased that may be returned and repurchased after December 13, 2024 in order to benefit from the temporary relief (e.g., kids toys already purchased for the holidays).
Suppliers should carefully determine if their goods are proposed qualifying goods before adjusting their systems as the qualifying goods are mostly consumer goods and trying to recapture from their customers any tax owed due to programming errors will likely not be possible.
Finance released a Backgrounder related to the proposed GST/HST relief. There is currently no related legislative proposal.
In the Backgrounder, Finance lists the following qualifying goods subject to the proposed tax relief:
Qualifying Goods
The following are descriptions of goods that would qualify for the proposed tax relief.
1. Children’s clothing: meaning garments (other than garments of a class that are used exclusively in sports or recreational activities, costumes, children’s diapers, or children’s footwear) that are:
2. Children’s footwear: meaning footwear (other than stockings, socks or similar footwear or footwear of a class that is used exclusively in sports or recreational activities) that is designed for babies or children and has an insole length of 24.25 centimetres or less.
3. Children’s diapers: meaning a product designed for babies or children and that is a diaper, a diaper insert or liner, a training pant, or a rubber pant designed for use in conjunction with any of those items.
4. Children’s car seats: meaning a restraint system or booster seat that conforms to the Canada Motor Vehicle Safety Standard 213, 213.1, 213.2 or 213.5 under the Motor Vehicle Restraint Systems and Booster Seats Safety Regulations.
5. Print newspapers: meaning print newspapers containing news, editorials, feature stories, or other information of interest to the general public that are published at regular intervals. They would not include electronic or digital publications. They would also exclude most fliers, inserts, magazines, periodicals, or shoppers.
6. Printed books: including a printed book or an update of such a book, an audio recording where 90 per cent or more of it is a spoken reading of a printed book, or a bound or unbound printed version of scripture of any religion. However, they would not include:
7. Christmas trees or similar decorative trees: whether natural or artificial.
8. Food or beverages: items for human consumption that are:
9. Select children’s toys: a product that is designed for use by children under 14 years of age in learning or play and that is:
10. Jigsaw puzzles, for all ages.
11. Video-game consoles, controllers or physical game media (e.g., a video-game cartridge or disc).
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