Enhanced GST rental rebate: CRA opines that construction begins on excavation

Yesterday, the Canada Revenue Agency (“CRA”) announced that, in its view, the construction of purpose-built rental housing (“PBRH”) for purposes of the PBRH rebate under the Excise Tax Act is generally “considered to begin at the time the excavation work related to the residential complex begins.”

The CRA’s position would thus mean that developers who are currently building PBRH but began excavation before September 14, 2023 may not be eligible for the rebate. While it is clear that the rebate applies to certain construction beginning after September 13, 2023, this represents the first time the CRA has stated its view on when “construction” is considered to “begin”.

Our prior blog post discusses the rebate in greater detail.

Prepared by: Adrian Zee

Adrian is an associate at the firm’s Vancouver office. Adrian’s practice focuses on Canadian commodity tax, including the Harmonized Sales Tax (HST), Goods and Services Tax (GST), provincial sales taxes, and realty taxes (including the B.C. Speculation and Vacancy Tax, City… more »

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