RTI – Court of Quebec confirms that it had no jurisdiction to deal with over-remittances of source deductions

Couture JCQ confirmed that the Court of Quebec had no jurisdiction to consider a Notice of Objection of the taxpayer based on the failure of the ARQ to refund source deductions which it alleged that it had over-remitted, given that the Quebec equivalent of ITA s. 171(1) only accorded the Court of Quebec jurisdiction to deal with assessments. Here, there was no assessment that had been objected to.

Neal Armstrong. Summary of RTI Turbo Inc. v. Agence du revenu du Québec, 2025 QCCQ 231 under s. 171(1).