Section 3
Administrative Policy
GST/HST Memorandum 19-3-9, Purpose-built Rental Housing Rebate, 3 November 2025
Substantial renovation if all but foundation is removed
- Examples 10 and 11. Excluded renovated housing supply where all but the existing foundation is demolished , but not if also the foundation is removed.
Section 4
Subsection 4(2)
Administrative Policy
GST/HST Memorandum 19-3-9, Purpose-built Rental Housing Rebate, 3 November 2025
Application of s. 190(1) to produce a deemed conversion of an office building to a prescribed property
40. Where a person converts non-residential real property, such as an office building, into a multiple unit residential complex, the residential complex is prescribed property where both of the following conditions are met:
- The multiple unit residential complex includes 4 or more residential units and at least 4 of those units each contains private kitchen facilities, a private bath, and a private living area; or 10 or more residential units
- At least 90% of the residential units that form part of the multiple unit residential complex are held for an eligible purpose that includes making certain exempt supplies of the unit or for making exempt supplies that include giving possession or use of a unit to a person for occupancy as an individual's place of residence
41. On September 13, 2023, the prescribed property must also have met all of the following prescribed conditions:
- It was in existence
- It was not in the process of being constructed
- It was not being used as a residential complex
Partial conversion to residential does not qualify
Example 7. No conversion to a MURC where the top floor was already residential
13 August 2024 GST/HST Interpretation 247663 - Strata-titled townhomes and the purpose-built rental housing (PBRH) rebate
The company acquired an existing single-family house in order to demolish it and construct two identical buildings, each containing four residential units for long-term rental use. It was unclear whether the municipal authority's bylaws required each unit to be strata-titled or whether it was only each of the two buildings that was required to be strata-titled.
Regarding the first alternative, CRA noted that a "multiple unit residential complex" (MURC) did not include a condominium complex, whose definition relevantly referred to a residential complex that contained more than one residential condominium unit. Accordingly, under the first alternative, there would be no eligibility for the purpose-built rental housing (PBRH) rebate.
Under the second alternative, each building could qualify as a MURC, so that if the other requirements were satisfied, e.g., regarding each of the four units therein having the requisite attributes, the units in each building could generate the PBRH rebate.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Multiple Unit Residential Complex | rental apartment building would not qualify as a MURC if it was required to be strata-titled | 156 |
Paragraph 4(2)(a)
Administrative Policy
11 October 2024 GST/HST Interpretation 247959 - Rebate for newly purchased 8-plex in […]
The correspondent was purchasing a block of newly-constructed dwelling units intended for long-term residential rental purposes. The block consisted of four separately titled properties, where each titled property contained two dwelling units with a private kitchen, private bathroom, private living area, and separate private entrance.
CRA indicated that the PBRH rebate would not be available, as each titled property contained only two residential units and therefore could not be considered a multiple unit residential complex. Furthermore, this issue could not be remedied by consolidating the block of dwelling units into a single title after the purchase, since this testing was not met at the time of the purchase.
14 August 2024 GST/HST Interpretation 247708 - […][the Company] and the purpose-built rental housing (PBRH) rebate
The company will construct two duplexes, each containing two qualifying residential units, including separate kitchens, baths, and private living areas, on one legal title. The two buildings might be connected by a hallway. CRA stated:
Where there are two separate buildings each containing residential units, there would generally be two separate residential complexes because a residential complex includes, among other things, a building (or a part of a building).
Accordingly, as two separate buildings each only containing two units, they did not qualify as prescribed multiple-unit residential complexes for purposes of the purpose-built rental housing (PBRH) rebate.
Whether a connecting hallway could render the two structures as one building so that they could qualify was a question of fact, whose determination took into account such factors as “the degree of structural connectivity, the degree of annexation, the degree of functional independence (such as separate mechanical systems for heating, cooling, electrical, etc.), and the provisions of any applicable by-laws or planning laws with respect to structures on the property.” If the correspondent wished this determination to be made, it should “provide further information such as structural plans and drawings with a further explanation of how these two structures will function as a single building along with a copy of applicable by-laws or planning laws with respect to the type of structure or structures that may be constructed on the subject property.”
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Residential Complex | separate buildings on the same land are separate residential complexes | 94 |
3 September 2024 GST/HST Interpretation 247914 - Eligibility for the purpose-built rental housing rebate and duplexes
Two side-by-side rental buildings (described as two duplexes) with a common wall each contained two “qualifying residential units” (as defined in s. 256.2(1)) including separate kitchens, baths, and private living areas, would qualify as four-unit multiple-use residential complexes (MURCs) for purposes of the purpose-built rental housing (PBRH) rebate, given that they were being constructed after September 13, 2023, on one legal title.
Paragraph 4(2)(b)
Administrative Policy
GST/HST Memorandum 19-3-9, Purpose-built Rental Housing Rebate, 3 November 2025
Owner unit disqualifies
- Example 3. Project maintained its October 31, 2021 excavation-commencement date notwithstanding that the project was then sold while only the complex shell was completed - and changed by the purchaser to a MURC rather than condo project.