CRA indicates that s. 163(2) can extend to false statements (not just returns) provided to CRA for ITA purposes

2010-0356511I7 found that a false invoice produced on audit did not directly engage s. 163(2). CRA indicated that this would no longer be its view in light of a 1998 amendment to s. 163(2), which replaced the reference to inter alia a false statement in a return (broadly defined to include a “statement or answer”) filed or made “as required by or under this Act or a regulation” with a reference to a false statement in a return filed or made “for the purposes of the Act.”

CRA indicated that in light inter alia of this amendment, which “broaden[ed] the application of the penalty … to a false statement or omission made ‘for the purposes of this Act’,” s. 163(2) could now extend, for example, to false documents submitted to support a request to amend a return.

Neal Armstrong. Summary of 24 June 2025 Internal T.I. 2022-0956161I7 under s. 163(2).