CRA is refusing requests for Canadian branches of foreign FIs to register for GST/HST purposes
A Canadian branch of a foreign financial institution that has imported taxable supplies potentially may reduce its compliance burden (i.e., less frequent returns and payments – but with the potential to then be required to file an annual information return) if it voluntarily registers for GST/HST purposes.
However, the CRA is increasingly refusing such applications; its reason is that the existence of a Canadian branch does not make the financial institution a Canadian resident for GST/HST purposes. …
This is puzzling since ETA s. 132(2) provides that a non-resident person with a permanent establishment in Canada is considered to be resident in Canada in respect of the person's activities carried on through that establishment.
Neal Armstrong. Summary of Andrew Linton and Jillian Adams, “CRA Denies Voluntary GST/HST Registration for Financial Institutions,” Canadian Tax Focus, Vol. 9, No. 4, November 2019, p. 7 under ETA s. 240(3).