Objections overview

An objection is a document you file if you think the Canada Revenue Agency (CRA) misinterpreted the facts of your tax situation or applied the tax law incorrectly. It gives you an opportunity to have your say about your GST/HST assessment or reassessment.

When you file a GST/HST objection, the CRA reviews all the information you provided before making a final decision about your case. If the CRA agrees with you, in whole or in part, they will adjust your tax return and send you a notice of reassessment. If the CRA disagrees with you, they will inform you that the assessment or reassessment you disputed was correct.

Conditions for filing an objection

You have to be objecting to either:

• a notice of assessment or
• a notice of reassessment

You cannot file an objection to a statement of account or a proposal letter from an auditor explaining the reason for the proposed assessment or reassessment.

If the CRA assessed you for the debts of another individual or corporation, you should call the telephone number on your memorandum assessment to discuss your dispute before you file an objection.

Deadline for filing an objection

You have to file a GST/HST objection within 90 days from the date of your notice of assessment or reassessment.

Extension to the deadline

If you did not file your objection on time because you tried to resolve your issue with the CRA office responsible for sending your assessment or reassessment, or because of circumstances beyond your control, you can apply for an extension. You can do this at the same time as you file your notice of objection.

You must explain why you did not file your objection on time and give the facts and reasons of your objection. You can apply for an extension up to one year after the deadline for filing an objection by writing to the Chief of Appeals at your Appeals Intake Centre.

How to file an objection

When you file a GST/HST objection, you must provide clear details of the issues you are objecting to, including why you disagree with your assessment. Include all relevant facts and supporting documents.

In addition, specified persons must also describe each issue they are objecting to, specify the amount of relief sought for each issue and provide the facts and reasons for each issue.

In the province of Quebec

Revenu Québec generally administers the GST/HST in Quebec. To get information on the time limits and how to file an objection to a GST/HST assessment, contact Revenu Québec.

The CRA is responsible for administering the GST/HST and Quebec sales tax that apply to selected listed financial institutions (SLFIs).

Selected listed financial institutions that are objecting to the GST component should follow the steps described below for all other provinces and territories. If they are objecting to the QST component, they have to print and complete Form RC375, Notice of Objection (QST) for Selected Listed Financial Institutions.

In all other provinces and territories

File a GST/HST objection online

To file a GST/HST objection online, log into My Business Account, and select “Register my formal dispute” (notice of objection). When you register online, you will automatically receive a case number that you need to include when submitting documents. To submit supporting documents online, select Submit documents online. Your objection will be sent directly to the Appeals Division for validation and review.

File a GST/HST objection through your representative

You can have your authorized representative file a GST/HST objection on your behalf. They can use Represent a Client and select “Register my formal dispute” (notice of objection).

File a GST/HST objection by mail or fax

To file a GST/HST objection, print and complete Form GST159, Notice of Objection (GST/HST) and mail or fax it to the Chief of Appeals at your Appeals Intake Centre.

You can send your objection to the Appeals Intake Centre at the following address:

Chief of Appeals
Appeals Intake Centre
1050 Notre Dame Avenue
Sudbury ON
P3A 5C1

Fax numbers:

705-670-6649 or 1-866-443-4955

604-587-2672 or 1-866-489-6832

If you have supporting documents to include with your objection, you can send them by mail, fax or online through the CRA's Submit documents service. For more information, go to Submit documents online.

When your objection will be processed

Objections are resolved case by case and their processing times vary depending on their level of complexity.

For information on the different complexity levels of objections, timelines and how to get updates on your objection, go to Processing times and complexity levels-Income tax and GST/HST objections

When to pay amounts owing

Pay when you file an objection

Even if you filed a notice of objection for your GST/HST assessment, the CRA can continue to collect amounts you owe.

Interest charges still apply to an amount owing while it is in dispute. You can pay all or part of the amount in dispute to avoid having to pay more interest.

To learn about payment methods, go to Make a payment to the CRA.

If the CRA agrees with your objection, they will send you a refund, with interest, for the amounts you paid.

If you cannot pay your tax debt

Ignoring your debt does not make it go away. If you cannot pay the full amount you owe, you can make a payment arrangement. It's up to you to contact the CRA to resolve your situation and avoid paying more interest on what you owe.

The CRA can grant relief from penalty or interest, but only in certain circumstances.

Disagreeing with the CRA's decision

If you disagree with the CRA's decision on your objection, you can File an appeal in Court-income tax or GST/HST.

Forms and publications

• Form GST159, Notice of Objection (GST/HST)
• 31-0 GST/HST Memorandum 31, Objections and Appeals