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8 January 2026

Canada's GST/HST Reverse Charge Mechanism (RSM) 2025: Complete Guide For Telecom Providers, Telecom Resellers Facing New Anti-Carousel Fraud Rules

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Rotfleisch & Samulovitch P.C.

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Rotfleisch Samulovitch PC is one of Canada's premier boutique tax law firms. Its website, taxpage.com, has a large database of original Canadian tax articles. Founding tax lawyer David J Rotfleisch, JD, CA, CPA, frequently appears in print, radio and television. Their tax lawyers deal with CRA auditors and collectors on a daily basis and carry out tax planning as well.
The GST/HST reverse charge mechanism introduced in Budget 2025 marks a significant shift in how Canadian telecom businesses handle GST/HST on specified telecommunication services.
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Overview of Canada's New GST/HST Reverse Charge Mechanism for Telecom Fraud Prevention in 2025

The GST/HST reverse charge mechanism introduced in Budget 2025 marks a significant shift in how Canadian telecom businesses handle GST/HST on specified telecommunication services.

This new GST/HST reverse charge mechanism transfers the obligation to calculate, report, and remit GST/HST from the supplier to the GST/HST-registered recipient, targeting carousel fraud in telecommunication services.

Experienced Canadian tax lawyers strongly recommend that telecom resellers, VoIP providers, cloud communication platforms, wholesalers, and even crypto businesses dependent on telecommunication services master the GST/HST reverse charge mechanism now—before the rules become law in 2026.

Why Canada Introduced the GST/HST Reverse Charge Mechanism: Combatting Carousel Fraud in Telecommunication Services

GST/HST carousel fraud has cost the Canada Revenue Agency billions through fake supply chains where a "missing trader" collects GST/HST but never remits it. The federal GST/HST reverse charge mechanism directly attacks this fraud by making the recipient—not the supplier—responsible for the GST/HST when purchasing specified telecommunication services for resale.

Quebec pioneered a similar concept in 2016 with the Attestation de Revenu Québec, while the European Union has successfully used a broad VAT reverse charge mechanism for decades. In the United States, certain states impose a limited sales tax reverse charge on out-of-state services, but Canada's federal GST/HST reverse charge mechanism for telecommunication services is the country's first nationwide application at the federal level.

How the GST/HST Reverse Charge Mechanism Works for Specified Telecommunication Services

Under the new GST/HST reverse charge mechanism, "specified telecommunication services" include:

  • Real-time or near-real-time voice communication (e.g., Voice over Internet Protocol or VoIP minutes), and
  • Bundled transmission of text, images, sound, or data tied to voice capability.

When a GST/HST-registered business acquires these telecommunication services primarily for resale, the GST/HST reverse charge mechanism requires the recipient to:

  • Self-assess the GST/HST on the purchase price
  • Report and remit the GST/HST on its own GST/HST return, and
  • Claim a full input tax credit in the same return (resulting in zero net GST/HST for legitimate resellers).

Suppliers must issue invoices clearly stating "subject to GST/HST reverse charge mechanism" and must not charge or collect GST/HST. This eliminates the risk of the supplier disappearing with the tax—the core weakness exploited in GST/HST carousel fraud.

Key Compliance Impacts of the GST/HST Reverse Charge Mechanism on Canadian Telecom Businesses

Telecom wholesalers, VoIP resellers, cloud telephony providers, and large purchasers of telecommunication services must update systems and contracts immediately to comply with the GST/HST reverse charge mechanism. Failure to self-assess correctly can lead to denied input tax credits, interest, and penalties.

Crypto mining farms, decentralized finance platforms, and data centres that consume significant telecommunication services should also prepare, as future expansions of the GST/HST reverse charge mechanism could capture additional digital or high-risk supplies.

Pro Tax Tips – Mastering the GST/HST Reverse Charge Mechanism for Telecom Compliance

  • Amend all telecommunication service contracts to reference the GST/HST reverse charge mechanism.
  • Configure accounting software to auto-calculate GST/HST under the reverse charge on qualifying telecommunication services.
  • Train accounts payable staff to reject any invoice that incorrectly charges GST/HST on reverse-charge telecommunication services.
  • Maintain clear documentation proving telecommunication services are acquired for resale to protect input tax credit claims.
  • Conduct a full GST/HST reverse charge mechanism readiness review with a Canadian tax lawyer before 2026 implementation.

Frequently Asked Questions About Canada's GST/HST Reverse Charge Mechanism for Telecommunication Services

What triggers the GST/HST reverse charge mechanism?

Purchase of specified telecommunication services by a GST/HST-registered recipient primarily for resale.

Who pays the GST/HST under the reverse charge mechanism?

The recipient self-assesses and remits the GST/HST.

Can the recipient recover the GST/HST?

Yes—100% recoverable as an input tax credit if acquired for taxable (resale) purposes.

When does the GST/HST reverse charge mechanism take effect?

Expected 2026, after the consultation period ending January 12, 2026.

Will the GST/HST reverse charge mechanism expand beyond telecommunication services?

Budget 2025 grants regulation-making authority for future extensions.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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