Pre-rulings pilot project from CRA

The CRA pilots a project offering pay-per-use consultations to help taxpayers and advisers determine whether to request a ruling on technical tax issues.

As part of a one-year pilot project, Canada Revenue Agency (CRA) plans to offer a new “Pre-Ruling Consultation” service via teleconference, to taxpayers and/or their advisers. The Joint Committee on Taxation of the Canadian Bar Association and Chartered Professional Accountants of Canada (CPA Canada) are working with CRA on the optimal design of the new process.

The Pre-Ruling Consultation will allow you to discuss a unique, new technical issue that is critical to a seriously proposed transaction with CRA income tax rulings professionals before you submit any ruling request. The objective is to reduce the likelihood of the taxpayer incurring significant and unnecessary costs by submitting a request for a ruling that the CRA would not provide.

The new process, which is still in the planning stage, offers an efficient and cost-effective way to help taxpayers and advisers to gain certainty over the sustainability of their tax positions. As the service will be provided in return for hourly fees, CRA aims to encourage serious ruling requests on unique technical issues only.