Reporting platform operators may be required to infer the consideration paid to platform vendors from the dollar value of their orders

The operator of a proprietary digital platform, who was also an equipment manufacturer, allowed independent vendors to list their goods for sale on the platform to select customers. Orders were initiated via the platform by such customers, but once confirmed, the platform was no longer involved in the transaction, which was completed by the vendors in the same manner as sales made outside of the platform. The operator had access to order data captured at the time of transaction initiation, such as the value of the orders, but had no visibility into subsequent developments, such as fulfillment and final sale price.

Regarding what inferences the reporting platform operator could make in relation to its reporting obligations under s. 292, CRA indicated that, generally, if a particular seller was determined by a reporting platform operator to be a reportable seller, CRA expected the operator to report the information set out in s. 292, including the total consideration paid or credited during each quarter of the reportable period. CRA indicated that if the reporting platform operator knew the total value of orders placed with the seller, this could make the seller's consideration "reasonably knowable" to the reporting platform operator as per the definition of consideration.

Neal Armstrong. Summaries of 30 May 2025 External T.I. 2025-1050201E5 under s. 288(1), s. 282(1) – consideration, active seller.