A March 28, 2024 Technical Interpretation (246427, Batoul Hasan) considered the collection of GST/HST by accommodation platforms on behalf of accommodation providers.

which party must collect and remit GST/HST

As of July 1, 2021, GST/HST began applying to all supplies of short-term accommodation in Canada facilitated through a digital platform (also referred to as an accommodation platform, see VTN 478(6020)). GST/HST was required to be collected and remitted by the supplier, who would be:

• the actual supplier of the accommodation (i.e. property owner), referred to herein as the “accommodation provider,” if they were registered for GST/HST; or
• the accommodation platform, where the accommodation provider was not registered for GST/HST (Subsections 211.13(3) and (4));

Since the rules were implemented in 2021, some accommodation platforms considered themselves to be the supplier of the accommodations even where the accommodation provider was registered and provided their GST/HST number to the accommodation platform. The accommodation provider never received the GST/HST and did not know how much was collected; therefore, was not able to include the transaction in their filings.

CRA does not intend to collect the same tax twice

CRA confirmed that they do not intend to collect tax twice on the same supply. Where the supplier and another person are both required to account for the tax, the liability to account for the tax of the supplier or the other person will be discharged where one of them accounts for the tax in its tax filings and remits the appropriate amount to CRA. These comments are covered in Policy Statement P-131R, which is subject to certain exceptions and its application is at CRA’s discretion at the time of an audit and based on the facts of the case at hand.