Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada.
Excise and Specialty Tax Directorate
5th floor, Tower A, Place de Ville
320 Queen Street
Ottawa ON K1A 0L5
[Company]
[Address]
Attention: [Client]
May 19, 2026
Dear [Client]:
Subject: Excise interpretation
Digital Signatures on Exemption Certificates
Thank you for your correspondence of [MM/DD/YYY], with respect to the application of the Select Luxury Items Tax Act (the Act) as it pertains to digital signatures on exemption certificates.
STATEMENT OF FACTS
Based on your letter, the following is our understanding of the facts provided:
1. You would like to be able to accept exemption certificates that are digitally signed.
2. Digitally signed exemption certificates would facilitate a quicker turnaround with your automotive dealers.
INTERPRETATION REQUESTED
You would like the Canada Revenue Agency (CRA) to clarify the use of digital signatures on exemption certificates as required under subsection 19(1) of the Act. You would also like to confirm whether the use of a digital signature through a software application such as […] is acceptable in completing the form.
INTERPRETATION GIVEN
An exemption certificate requires a signature from an authorized person certifying that the form is correct and complete. The signature may be handwritten or digital.
Under subsection 19(1) of the Act, the luxury tax under section 18 in respect of a subject vehicle sold by a vendor to a purchaser is not payable if an exemption certificate applies in respect of the sale of the subject vehicle in accordance with section 36 and if the vendor is a registered vendor in respect of subject vehicles.
The Minister requires that form L-100, Luxury Tax Exemption Certificate for Subject Vehicles be used as the exemption certificate; it must be signed by an authorized person, and a digital signature is acceptable. A digital signature can be any form of electronic representation that can be linked or attached to the document.
The primary function of a signature is to provide evidence of a signatory’s identity, intent to sign, and agreement to be bound by the contents of the document. As long as the digital signature links the purchaser to the document and provides evidence that the purchaser intends to be bound to the contents of the form, a digital signature will suffice.
The use of a third-party digital signature solution, such as […], is considered appropriate, and should be based on industry-accepted standards.
DISCLAIMER
The interpretation provided in this letter, including any additional information, is not a ruling and does not bind the CRA with respect to a particular situation. Future changes to the Act, regulations, or the CRA’s interpretative policy could affect the interpretation or the additional information provided herein.
CONTACT
If you require clarification with respect to any of the issues discussed in this letter, please call me directly at 343-484-3305.
Sincerely,
Christopher Warren
Manager (Acting)
Luxury Tax Unit
Excise Tax and Fuel Charge Division
Excise and Specialty Tax Directorate
Legislative Policy and Regulatory Affairs Branch
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