Section 239

Subsection 239(1) - Authority for Separate Returns

Administrative Policy

GST/HST Memorandum 2.4 Branches and Divisions, May 1999

Written application on GST10 or by telephone

2. … Application may also be made by telephone, provided all required information is available. …

Branches do not have separate existence

4. The branches and divisions as part of one legal entity are not required to charge GST/HST on the transfer of property or services between one another.

5. The branches and divisions authorized to file separate returns are required to have the same fiscal year and reporting periods as the parent. As well, certain elections made by a parent will apply to all its branches and divisions.


A parent company with two filing branches (i.e., three separate activities or locations in total) is eligible to file separate GST/HST returns, and elects to file returns monthly. It also elects to use the quick method of accounting. The parent and the two filing branches must all file GST/HST returns monthly using the quick method.

Number still that of legal entity

6. The GST/HST Business Number is assigned to the legal entity (i.e., the parent) and the division or branch will receive a program account number. The branch or division account number is mainly for accounting purposes.


GST10"Application or Revocation of the Authorization to File Separate GST/HST Returns and Rebate Applications for Branches or Divisions"


Once we authorize you to file separate GST/HST returns and rebate applications for your branches or divisions, the authorization remains in effect until we revoke it in writing.

Subsection 239(2)


R. v. Chen, [2006] G.S.T.C. 38

reference to branch suffix was of not import

The appellant was charged with failure to file GST returns for a period of over eight years and raised, among other arguments, a discrepancy in the description of his GST number. The Court discussed the argument, and noted: “a Crown witness explained that a person such as Mr. Chen would have only one umbrella GST number, and in this case, Mr. Chen’s number was 135405025. The suffix RT0001 is simply a designation indicating that the particular account was the first account under Mr. Chen’s umbrella number. It was clear that the difference in the two descriptions of Mr. Chen’s GST number were of no moment.”

See Also

R 171 Enterprises Ltd. v. The Queen, 2004 TCC 36 (Informal Procedure)

company with 2 branches was one registrant for assessment purposes

Little J rejected the appellant's submission that "the Minister had reassessed the wrong taxpayer, and accepted (at para. 16) the respondent's submission that:

there is only evidence of one registrant in this situation and that registrant is the Appellant. ...[T]he numbers RT0001 and RT0002 used on the assessments were merely used as an "accounting facilitation".

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 296 - Subsection 296(1) branch account numbers were merely an accounting facilitation 50

Administrative Policy

GST/HST Memorandum 18-2 “Provincial Governments” February 2020

No supplies between branches of a provincial government

11. Generally, each provincial/territorial government, including all of its departments/ministries and some of its agencies, boards and commissions, has registered for GST/HST purposes under a single Business Number (BN) with various filing branches/divisions. All the provincial/territorial government entities under the particular BN for a province/territory collectively form the provincial/territorial government registrant. Other provincial/territorial government entities may be registered under a different BN from the provincial/territorial government registrant.

12. Transactions between entities that are branches/divisions of the same provincial/territorial government registrant are not treated as supplies for purposes of the GST/HST. Therefore, the provision of property or services between those entities within a provincial/territorial government registrant is not subject to the GST/HST.

October 28, 1997 Ruling RITS/No HQR0000804

replacement of DNR by CCRA required separate CCRA branch registration

After noting that the federal government registrant has applied for and been authorized to file separate returns for its branches and divisions and that by virtue of an amendment to Schedule II to the FAA, the federal government will include the CCRA, ruling that:

The proposed Canada Customs and Revenue Agency will not be required to register for GST/HST purposes as it will be part of the federal government registrant. However, if the Agency wishes to collect, report and remit tax in the same manner as the current Department of National Revenue, it will be required to apply for the authority to file separate returns.