CRA accommodates backdating a GST/HST registration by over six years in order to claim ITCs

A not-for-profit corporation registered for GST/HST purposes effective March 18, 2016, then got this registration backdated somewhat to January 1, 2016 – and then subsequently filed returns for the previous six years (2010 through 2015) and requested that its registration be further backdated to April 1, 2010 in order that it could claim input tax credits for tax paid since April 1, 2010. The Rulings Directorate was accommodating, stating that:

In order to backdate its registration, [Corporation A] could show it was a registrant during the period in question by proving it was not a small supplier; in other words, it was required to be registered.

The Directorate did not reference any limitation on claiming ITCs from before the four-year period referenced in ETA s. 225(4)(b).

Neal Armstrong. Summary of 19 March 2018 Interpretation 183900 under ETA s. 240(1) and s. 225(4)(b).