CRA indicates that it will use “discretion” in its first 12 months of administering the new GST/HST e-commerce rules
After discussing the legislative proposals, to generally take effect on July 1. 2021, regarding cross-border digital products and cross-border services (which it described as extending to “traditional services such as legal and accounting services … [supplied] to consumers in Canada”), goods supplied through fulfillment warehouses in Canada, and platform-based short-term accommodation, CRA stated:
Where the affected businesses and platform operators show that they have taken reasonable measures to comply but are unable to meet their new obligations for operational reasons, the CRA will take a practical approach to compliance and exercise discretion in administering these measures during a 12-month transition period, starting July 1, 2021.
Neal Armstrong. Summary of Excise and GST/HST News - No. 109, under “GST/HST measures relating to the digital economy,” June 28, 2021 under ETA [draft] s. 211.12(2).