Request a technical interpretation
The Income Tax Rulings Directorate of the Canada Revenue Agency (CRA) is responsible for interpreting the Digital Services Tax Act and issuing technical interpretations.
What is a technical interpretation
A technical interpretation explains the CRA’s interpretation of specific provisions of tax acts.
A technical interpretation:
- Is generic
- Is not binding on the CRA
- Might not cover all situations so it does not determine how the CRA will treat a specific situation
The CRA does not charge a fee for a technical interpretation.
What to include in your request
Your request must include:
- Name, address, and telephone number
- A description of the tax issue
- A technical analysis of the issue, which includes how you believe the CRA should interpret and resolve the issue as supported by section references to the Digital Services Tax Act or other relevant sources
How to submit your request
You can submit your request to the Income Tax Rulings Directorate by mail or email:
If you submit your request by mail
Send your request by mail to:
Income Tax Rulings Directorate
Canada Revenue Agency
5th floor, Tower A, Place de Ville
320 Queen Street
Ottawa ON K1A 0L5
If you submit your request by email
Send your request by email to: itrulingsdirectorate@cra-arc.gc.ca
The following authorization must be included with all technical interpretation requests where the requester wishes to communicate with the CRA by email:
Re: Technical Interpretation regarding the Digital Services Tax Act
Name: (Name of taxpayer)
I hereby authorize the CRA to email all correspondence concerning the technical interpretation request made on behalf of the above-noted taxpayer. The correspondence is to be transmitted to email address (insert email address).
I am aware that the CRA does not provide assurance with respect to the protection, confidentiality, or security of email transmissions. I accept the risks inherent in sending information by email. I agree not to hold the CRA or its employees liable for any damage or loss, however caused, arising out of the email transmissions of correspondence related to the technical interpretation request.
____________________________________________
Requester's name
____________________________________________
Requester's signature
____________________________________________
Date
This contact information is to be used only for technical interpretation requests regarding the Digital Services Tax Act. We will reply to your request only if it relates to a technical interpretation request regarding the Digital Services Tax Act.
Technical interpretation process
We will acknowledge your request within 2 weeks of receiving it. The acknowledgement will include a contact name and a file reference number.
We will notify you if your request:
- Is incomplete
- Relates to a circumstance where we will not provide an interpretation
Our policy is to give priority to technical interpretation requests made by other areas of the CRA. Generally, we answer requests for technical interpretations in the order we receive them. Our goal is to issue technical interpretations within 90 business days of receiving all required information.
Circumstances where we will not issue a technical interpretation
Sometimes, we cannot issue a technical interpretation. You can find these circumstances in paragraph 7 of Information Circular IC70-6R12, Advance Income Tax Rulings and Technical Interpretations.
Notes about IC70-6R12
- Paragraph 7(e) should be read as "situations described in paragraphs 19(e) to (l) below."
- Any reference to a ruling in paragraphs 19(e) to (l) means a technical interpretation.
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