26 February 2015 CBA Roundtable, Q. 33

Can a person claim input tax credits in a reporting period after its registration in respect of GST/HST paid in periods where the person was a registrant but not registered for GST/HST assuming it is otherwise within the limitation period? CRA responded:

[A] person can claim input tax credits (ITCs) in a return filed for a reporting period after it becomes registered in respect of GST/HST paid in reporting periods during which the person was a registrant, but not registered for GST/HST, assuming it is otherwise within the applicable ITC limitation period under subsection 225(4)…and all other legislative conditions have been met, including the ITC documentary requirements.

Under subsection 169(1)… one of the conditions for claiming an ITC is that the person must be a registrant during the reporting period in which the GST/HST becomes payable by the person… . A “registrant” is defined under subsection 123(1)… to mean a person who is registered, or who is required to be registered, for GST/HST purposes.

When the taxpayer becomes registered, it generally is entitled to claim input tax credits in its first post-registration return for GST that was previously incurred while it was a registrant (i.e., required to be registered.)