CRA generally will not assess interest where a “good” (ETA s. 186(1)-qualified) holding company does not self-assess itself for GST on imported taxable supplies

Although in a broad sense, ETA s. 186(1) treats a Holdco holding an Opco with an exclusive commercial activity the same as if it carried on the commercial activity itself, strictly speaking all that s. 186(1) does is entitle the Holdco to input tax credits on related purchases.  Accordingly, s. 186(1) does not apply to relieve Holdco of the obligation to self-assess itself for purchases of imported taxable supplies relating to Opco (and then claim an off-setting ITC).

However, CRA has now indicated that where a registrant fails to account for HST on an imported taxable supply which should have been self-assessed and has not claimed an ITC for those amounts, administrative tolerance generally will be exercised so that no interest is assessed.

Neal Armstrong.  Summary of CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 34 (available with membership password at http://www.cba.org/CBA/sections_NSCTS/main/GST_HST.aspx) under ETA, s. 217(1) – imported taxable supply.