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When does a Canadian virtual assistant agency need GST HST registration?
Virtual assistant agency GST HST registration in Canada: when CRA requires it, how to charge the right rate, and what happens if you skip registration.
What to take away
- A Canadian virtual assistant agency must register for GST/HST once its worldwide taxable supplies exceed CRA's small supplier threshold.
- Registration is with the Canada Revenue Agency, but the rate you charge depends on whether the client is in an HST province.
- You charge 5% GST in non-HST provinces and 13% or 15% HST in the five HST provinces.
- Skipping registration can mean CRA assesses the tax you should have collected, plus interest and penalties.
GST/HST registration is not a provincial business licence and it does not depend on whether your clients sign retainer agreements.
Federal and provincial jurisdiction
The Canada Revenue Agency administers GST and the federal part of HST for the whole country. Provinces that have harmonized their sales tax with the federal GST use a combined HST rate. Provinces without HST charge only the federal 5% GST, although Quebec, British Columbia and Manitoba apply separate provincial sales taxes that this article does not cover.
The table below shows the GST/HST rate for taxable supplies made in each province or territory.
| Province or territory | Tax type | Rate |
|---|---|---|
| Alberta, British Columbia, Manitoba, Northwest Territories, Nunavut, Quebec, Saskatchewan, Yukon | GST | 5% |
| Ontario | HST | 13% |
| New Brunswick, Newfoundland and Labrador, Nova Scotia, Prince Edward Island | HST | 15% |
CRA's GST/HST rates page explains when you charge based on the place of supply.
What triggers GST/HST registration
CRA's small supplier threshold is $30,000 in taxable supplies over four consecutive calendar quarters or in a single calendar quarter. 'Taxable supplies' includes most virtual assistant services, even if some clients are outside Canada, because the threshold counts worldwide revenue from taxable supplies. You must register by the first day of the second month after you cross the threshold. If you cross it in a single quarter, you must register immediately and start charging on the supply that put you over.
This is a good place to check whether your revenue includes amounts paid to contractors or only the agency's margin. For related classification questions, see CRA contractor rules for a virtual assistant agency.
Documents and information to submit
To register, you need a business number if you already have one for payroll or corporate tax. You also need your legal business name, the name and social insurance number of a director or owner, your fiscal year-end, your estimated annual taxable supplies, and your banking details for direct deposit if you want refunds paid electronically.
CRA's GST/HST account registration page sets out the steps. In practice, you can register through CRA's My Business Account or by completing Form RC1.
- Gather your business number and owner or director details.
- Estimate your taxable supplies for the next 12 months.
- Register online through My Business Account or submit Form RC1.
- Wait for your GST/HST account number before you charge tax.
Holding errors and omissions insurance does not remove the need to register; see errors and omissions policy cost.
How long CRA registration takes
CRA does not publish a guaranteed processing time. Online registration through My Business Account is usually immediate for the account number, but confirmation can take a few business days. Paper Form RC1 can take several weeks. If you need to charge tax right away, register before you need the number.
What happens if you skip it
If you cross the small supplier threshold and do not register, CRA can assess you for the GST/HST you should have charged from the date you crossed the threshold. You also owe interest on late remittances and may face a failure-to-register penalty. In serious cases, CRA can register you retroactively and directors can be held personally liable for unpaid amounts. The liability is not limited to the agency's bank balance.
Provincial, municipal and private rules
GST/HST registration is a federal tax obligation, but it sits alongside other rules. Provincial sales taxes, such as Quebec's QST or British Columbia's PST, are separate from GST/HST and do not change your federal registration requirement. Municipal business licences do not change your GST/HST duty, and some cities require a separate home-based business permit. Private retainer agreements cannot override the obligation to charge tax, but they should state whether fees are exclusive or inclusive of GST/HST. For client data rules that also apply to a Canadian agency, read PIPEDA for a Canadian virtual assistant agency.
Common questions
Do I need to register for GST/HST if all my clients are outside Canada? No, supplies made to non-resident clients are generally zero-rated if certain conditions are met, but you still need to track revenue and confirm place of supply. A Canadian agency with only foreign clients often remains a small supplier, so registration is optional until the threshold is crossed.
Can I charge GST/HST without registering? No, you cannot charge or collect GST/HST until CRA issues you a GST/HST account number. Charging tax while unregistered is an offence and you still owe the amount to CRA.
Does Canadian GST/HST apply to US clients? No, Canadian GST/HST generally does not apply to supplies made to non-resident clients, but US state tax may apply. For a state-by-state view, see sales tax in another state.
What if I register late, do I have to backdate tax on past invoices? If you should have registered earlier, CRA can assess tax on supplies from the date you crossed the threshold, even if you did not collect it from clients. That is why many agencies backdate their effective registration date.
