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New QST requirements for E-commerce businesses outside of Québec

Under the current Québec sales tax (QST) legislation, businesses based in Québec must be registered and must remit provincial sales tax. However, businesses who do not have a physical establishment in the province but who are selling goods / services to Québec consumers  via online sales are not currently required to register and remit QST. 

Many Québec-based businesses feel that this has created a competitive disadvantage, and as a result, effective September 1st, 2019, certain e-commerce businesses outside Québec will be required to register for the QST using a dedicated online service. 

Who will this affect?
  • If you are a Canadian business with no physical presence in Quebec and you are selling over $30,000 of taxable goods / services to Québec consumers via online sales (e.g., via website, online, email, etc.) you will have to register and collect QST (effective September 1st, 2019) 
    • For example: If you have a clothing store based out of British Columbia and you have an online store where customers can place orders, we would suggest you review your online sales to Quebec consumers for the past 12 months. If the amount exceeds $30,000 in sales, then your business would be required to register and remit QST. 
  • If you’re already registered for the QST, you don’t have to worry about this new requirement. 

NOTE: The new requirement will apply to non-resident suppliers, whether or not they are located in Canada.
 

Are you unsure as to whether you need to register?

Revenu Québec has created an interactive questionnaire for suppliers outside of Quebec that can help you determine whether you are subject to the new measure. Please note that it is possible for your results to be wrong; therefore, you can contact Revenu Québec directly and they will confirm whether you’re subject to this new measure. 

  • By telephone: 1 833 372-3850 (Canada and the U.S.: toll-free)
  • By email: [email protected] 
Where and when do I register?

Mandatory registration for Canadian businesses outside of Quebec must be completed by September 1st, 2019, and must be done online. Please see the “Registration Service for Suppliers Outside of Québec”. 

Registration is quick, easy, and simple. You will require the following to register: 

  • Legal business name;
  • 2 assigned representatives (e.g., business owner, admin, an accountant, etc.); and
  • General information about your business, such as what you sell. 

Once registered, you will receive an email including your QST number and confirming your account has been activated. 

NOTE: Revenu Québec will be issuing penalties after December 31st, 2019, for failure to comply.
 

When do I remit the QST?

Once you’re registered, you are required to collect QST at the rate of 9.975% on all purchases made by Quebec consumers, and remit it 4 times a year: 

  • If you register by September 1st, your first remittance would be due on October 31st, 2019.
  • Subsequent payments are due every 4 months, which corresponds to a calendar quarter (see here for quarterly deadlines). 
  • Payments are to be made directly online. 

NOTE: As for GST/HST must be remitted as usual to CRA (no changes to that effect)
 

How to easily determine whether or not QST must be collected

The following information will help determine whether or not QST must be collected: 

  • The customer’s billing address
  • Individual’s address
  • IP address of the device used or another geolocation method;
  • Payment-related bank information or the billing address used by the bank
  • Information from a SIM (Subscriber Identity Module) card; or
  • The place of the person’s landline.

As a small business owner you may want to retain some of your recipient’s information (as per PIPEDA, or as per your provincial privacy laws), in order to demonstrate whether or not the goods / services were delivered to a Québec consumer. 

For further help and information, please contact your CFIB Business Counsellor at 1-888-234-2232) or by email at [email protected].