CRA issues a Memorandum on the purpose-built rental housing rebate

CRA has issued a new GST/HST Memorandum on the purpose-built rental housing rebate. Points include:

• The requirement to have commenced construction after September 13, 2023, is interpreted as commencing the excavation for the project after that time, so that a prior excavation-commencement date would disqualify even if there was a subsequent change of owner and in the basic nature of what was being constructed.
• A unit owned by the owner of a multiple-unit residential complex (MURC) would not have a qualifying residential rental use for the purposes of the prescribed property definition, so that such unit would be required to represent under 10% of the units in the MURC in order for the MURC to be prescribed property.
• The deemed substantial renovation rule under subsection 190(1), where all but not a portion of a building is converted from commercial use (e.g., office use) to residential use, can qualify as a substantial renovation for purposes of engaging the rebate. This assumes that the property was not in the process of being constructed and was not being used at all as a residential complex on September 13, 2023.

Neal Armstrong. Summaries of GST/HST Memorandum 19-3-9, Purpose-built Rental Housing Rebate, 3 November 2025 under ETA s. 256(3.1), Real Property (GST/HST) Regulations. s. 4(2), s. 4(2)(b), s. 3.