CRA now indicates that it will only provide transitional administrative relief regarding the GST/HST “digital economy” measures where there is voluntary disclosure

Although CRA misleadingly refers to the 2021 Budget as having introduced, effective July 1, 2021, “GST/HST measures that related to the digital economy,” those measures are broader than that – essentially any non-resident making most types of supplies of services (other than financial services) or intangible personal property to Canadian recipients who are not registered must itself register for GST/HST purposes once it exceeds a de minimis threshold. In Excise and GST/HST News - No. 109, June 28, 2021, 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.

CRA has now substantially narrowed this relief, stating:

Before the CRA exercises its discretion in the administration of the new measures, an affected business or platform operator must first make a submission to the CRA requesting forbearance and obtain the CRA’s written approval that such discretion will be exercised. Submissions may be made to the CRA after July 1, 2021, until further notice.

Neal Armstrong. Summary of Excise and GST/HST News - No. 110 under the heading “Digital economy”, 8 December 2021 under ETA s. 211.12(2).