CRA postpones the implementation of its new GST/HST policy on trailing commissions

In 22 December 2025 GST/HST Interpretation 246664, CRA rejected a submission that GST/HST did not apply to dealer trailing commissions earned by a dealer (the “New Dealer”) who is not the dealer (the “Original Dealer”) who arranged the sale and issuance of the subject mutual fund trust units or shares, and concluded:

Effective July 1, 2026, mutual fund trailing commissions paid by [mutual fund] Managers to both Original Dealers and New Dealers will generally be subject to GST/HST.

However, on May 13, 2026, the CRA verbally informed various industry groups that it intends to grant a material extension to the implementation deadline for this new policy; and that it will provide further details regarding the enforcement of its administrative position in a notice to be published by the end of the month.

Neal Armstrong. Summary of EY Tax Alert – Canada, “CRA intends to postpone new administrative position on GST/HST treatment of trailing commissions,” 2026, Issue No. 30, 14 May 2026 under ETA s. 123(1) – asset management service.