CRA agrees that the concept of reporting platform operators collecting “business registration numbers” from Canadian-resident sellers is inapplicable

S. 284(2) requires (digital) reporting platform operators (RPO) to collect a taxpayer identification number (TIN) and a business registration number (BRN) in respect of a seller other than an excluded seller. However, s. 284(4)(a) provides that a TIN or BRN is not required to be collected if the jurisdiction of residence of the seller does not issue a TIN or BRN to the seller.

CRA agreed with the view that s. 284(4)(a) does not require RPOs to collect BRNs in respect of Canadian resident entity sellers, on the basis that Canada does not issue such a number.

A TIN is defined in s. 282(1)(a) as the number used by the Minister to identify an individual or entity, including a business member. Although a BRN is not defined in the ITA, the OECD commentary indicates that this references “high integrity number” functional equivalents of TINs for jurisdictions that do not issue TINs. Although the provinces may issue BRNs, Canada does not – hence the conclusion.

Neal Armstrong. Summary of 25 January 2024 External T.I. 2023-0990781E5 under s. 284(2)(d).