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- What
An investment limited partnership (ILP) that is authorized to sell or distribute its interests across multiple provinces including a participating HST province (i.e., New Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario and Prince Edward Island) (HST Province) and/or Québec, or whose investors reside in these provinces, is required to calculate the provincial portion of the HST and the amount of QST payable for a given calendar year based on its percentage of business attributable to each HST Province and Québec.
To determine its business percentage in the relevant provinces for the 2025 calendar year, the ILP must obtain certain investor information as of September 30, 2025. The ILP should make a written request to its investors during the 2025 calendar year, except for investors who are required under the legislation to provide the information without a formal request from the ILP.
- Who
- An ILP is a limited partnership, the primary purpose of which is to invest funds in property consisting primarily of financial instruments and, if:
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- it is represented or promoted as a hedge fund, investment limited partnership, mutual fund, private equity fund, venture capital fund or other similar collective investment vehicle; or
- 50% or more of the total value of all the interests in the ILP is held by listed financial institutions.
- An ILP is subject to the rules related to the request for information for the 2025 calendar year if, at any time, during the year:
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- it is qualified, under the laws of Canada or a province, to sell or distribute its interests in several provinces, at least one of which is an HST Province and, for QST purposes only, in Québec and at least in one other province; or
- its investors reside in multiple provinces, at least one of which is an HST Province and, for QST purposes only, in Québec and at least in one other province.
Investor obligations
- The investors are generally required to provide, upon receiving a written request from the ILP, the required information as of September 30, 2025, except for investors who:
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- hold interests or category of interests with a total value of less than CA$10,000,000 as of September 30, 2025; and
- are investment plans other than distributed investment plans.*
These investors are required to provide the information mandated by the legislation no later than November 15, 2025, without the ILP being required to issue a written request.
*The terms "investment plan" and "distributed investment plan" are defined in the legislation.
- How
With respect to the 2025 calendar year:
- Although an ILP is required under the legislation to send the written information request to its relevant investors no later than December 31, 2025, the ILP should send the written request as soon as possible.
- Investors required to respond to an ILP's written request must provide the requested information to the ILP on or before the later of November 15, 2025, or 45 days after the day it received the written request.
- The investors required to provide the required information without the written request of the ILP, must provide it on or before November 15, 2025.
- Default
If the ILP does not have all the required information by December 31, 2025, it may be required to pay a higher amount of the provincial portion of the HST as well as an increased amount of QST.
- Where
Section 52 of theSelected Listed Financial Institutions Attribution Method (GST/HST) Regulations(SOR/2001-171, as amended).
Sections 433.25 to 433.32 of theAct Respecting the Québec Sales Tax(C.Q.L.R., c. T-0.1).
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