18 October 1995 GST/HST Interpretation 11650-10,11690-1 - Documentary Requirements - Business Number

Dear XXXXX

This letter is in response to an e-mail message, dated March 15, 1995, from XXXXX . XXXXX raised two issues with respect to the "Business Number" ("BN"):

•   whether there is any impact by the implementation of the BN on the documentary requirements specified in subsection 223(1) of the Excise Tax Act ("ETA") and the regulations adopted under the authority of paragraph 169(4)(a) (the Input Tax Credit Information Regulations - SOR 91/45);

•   whether the first nine digits of the BN will meet documentary information requirements for claiming input tax credits ("ITCs") where the registration number is required.

The BN has 15 digits. The first 9 digits of the number identify each business. For businesses converting existing GST numbers will become the first 9 digits of the BN. The last 6 digits of the BN will consist of an account identifier, for example, to identify a business's GST account.

Subsection 223(1) of the ETA requires a supplier to disclose the amount of tax paid or payable for a supply or to state that an amount paid or payable includes the GST. This disclosure obligation applies regardless of whether the recipient is entitled to an ITC. The BN initiative does not affect the operation of subsection 223(1) as the disclosure requirement does not include a requirement to provide the GST registration number.

The Input Tax Credit Information Regulations ("Regulations") prescribe the information that must be obtained by a registrant before claiming an ITC. Where the total amount paid or payable in respect of a supply is $30 or more, the supporting documentation must include the registration number assigned to the supplier pursuant to section 241 of the ETA (reference, subparagraph 3(b)(ii) of the Regulations).

The BN is a number assigned by the Minister to a registrant as a method of identifying the registrant. Section 241 is the authority for the Minister to assign a registration number to a registrant. While the BN is a registration number for the purposes of the ETA, the fact that the same number may be used for purposes of other legislation does not change its status under the ETA. The first nine digits of the BN, which are the person's registration number, will meet the documentary information requirements under the Regulations.

If you require any further information on this issue, please contact Raymond Labelle at (613) 952-8815.

H.L. Jones
Director
General Applications Division
GST Rulings and Interpretations

GTP: 1178(REG) XXXXX