Canada Tax Court Issues Decision Clarifying GST Installment Payment Obligations, Use of Prior-Year Credits

The Canadian Tax Court June 2 issued Decision No. 2026 CCI 107, clarifying GST installment payment obligations and the use of prior-year credits. The taxpayer, a legal service provider, used excess GST installments from its 2019 period to offset installments due for 2023 without making additional payments. The Revenue Quebec assessed interest for late installments, while the taxpayer claimed that the prior credit should be treated as a payment or prepayment of its 2023 liabilities. On appeal, the Tax Court found that: 1) taxpayers must make installment payments in the manner and time prescribed, and that a prior credit balance ...