GST/HST for Canadian Bitcoin Miners: Why You Probably Cannot Claim Input Tax Credits
Reference, not tax advice. This page describes what the Excise Tax Act says. It does not describe your situation, does not compute anything for you, and does not recommend a filing position. GST/HST outcomes turn on facts — whether you are registered, how you are paid, whether you mine in a pool or for an identified person, and whether hosting is involved. Talk to a Canadian tax professional before you act on any of it. Québec administers QST separately through Revenu Québec.
Quick answer
Most Canadian miners assume that because they buy hardware and electricity to run a business, they can register for GST/HST and claim input tax credits on those purchases. For mining itself, the Excise Tax Act generally says otherwise. Section 188.2 defines a cryptoasset "mining activity" — validating transactions and adding them to a public ledger, maintaining that ledger, or contributing computing resources to either — and then deems both the mining activity and the mining payment NOT to be a supply. It goes further: property or services you acquire, import or bring into a province for use in mining are deemed to be acquired otherwise than in the course of commercial activities. That second deeming is the mechanism, because input tax credits exist only for inputs to commercial activity. There is a real exception in subsection 188.2(5) for mining performed for another person whose identity is known, subject to conditions.
Do not assume the GST/HST you pay on rigs and power is recoverable — for mining activity the Act generally deems it not to be. Check whether your arrangement falls in the s. 188.2(5) exception before registering on that basis, keep the GST/HST question separate from the income-tax question because they follow different rules, and get a professional to look at pool and hosting arrangements specifically. This page states the statutory rule; only your own facts decide how it lands.
The rules, each tied to Excise Tax Act text
Every row names the governing provision. The “common mistake” field is the part worth reading twice — it is where Canadian miners actually go wrong.
GST/HST — mining activity and mining payment deemed not a supply (ETA s. 188.2(4)) high confidence
- The rule
- ETA s. 188.2(4) provides: "For the purposes of this Part, if a person receives a mining payment in respect of a mining activity, (a) the provision of the mining activity is deemed not to be a supply; (b) the provision of the mining payment is deemed not to be a supply; and (c) in determining an input tax credit of another person that provides the mining payment, no amount is to be included in respect of tax that becomes payable, or is paid without having become payable, by the other person in respect of any property or service acquired, imported or brought into a participating province for consumption, use or supply in the course of, or in connection with, the provision of the mining payment by the other person." The defined terms in s. 188.2(1) do the work. "Mining payment" means "money, property or a service that is a fee, reward or other form of payment and that is received or generated as a consequence of the mining activity being performed." "Mining activity" means an activity of (a) validating transactions in respect of a cryptoasset and adding them to a publicly distributed ledger on which the cryptoasset exists at a digital address; (b) maintaining and permitting access to such a ledger; or (c) allowing computing resources to be used for the purpose of, or in connection with, activities described in (a) or (b). "Cryptoasset" means property (other than prescribed property) that is a digital representation of value and that only exists at a digital address of a publicly distributed ledger. Because GST/HST under Part IX attaches to taxable supplies, the effect of the deeming in paragraphs (4)(a) and (b) is that there is no supply in respect of which tax could be exigible on the mining activity or on the payment for it. Subsection (4) does not stand alone. Subsections 188.2(2) and (3) deem property or services acquired, imported, brought into a participating province, consumed, used or supplied in the course of or in connection with mining activities to be acquired or used "otherwise than in the course of commercial activities" of the person. That is the input-side counterpart: no commercial activity means no input tax credit entitlement on those inputs. EFFECTIVE DATE: s. 188.2 is deemed to have come into force on February 5, 2022, not on the June 22, 2023 royal assent of the enacting Act. S.C. 2023, c. 26, s. 118(2) reads: "Subsection (1) is deemed to have come into force on February 5, 2022 except that, in determining an input tax credit of a person, paragraph 188.2(4)(c) of the Act, as enacted by subsection (1), does not apply in respect of property or a service acquired, imported or brought into a participating province before February 6, 2022." The consolidated section as reviewed carries no amendment other than the original enactment.
- Authority
- Excise Tax Act, R.S.C. 1985, c. E-15, s. 188.2 — s. 188.2(1) (definitions of "cryptoasset", "mining activity", "mining group", "mining group operator", "mining payment"), s. 188.2(2) and (3) (deemed non-commercial activity), s. 188.2(4) (deemed not a supply; ITC denial to the provider of the mining payment), s. 188.2(5) (exception). Enacted by the Budget Implementation Act, 2023, No. 1, S.C. 2023, c. 26, s. 118 (royal assent June 22, 2023). Coming-into-force and transitional rule at S.C. 2023, c. 26, s. 118(2). Verified against the Justice Laws consolidation current to 2026-05-26; s. 188.2 shows no amending citation other than 2023, c. 26, s. 118. No CRA guide, folio, memorandum or published interpretation applying s. 188.2 was located.
- Who it applies to
- Applies to any person, for GST/HST purposes, that performs a mining activity as defined and receives a mining payment — potentially covering block subsidies, transaction/priority fees and pool distributions, but only to the extent a given receipt falls within the s. 188.2(1) definition of "mining payment" arising from a "mining activity". That characterisation is a question of fact and contract, not something the section settles in advance for any particular arrangement. Paragraph (4)(c) operates on the payer side — typically a mining group operator or pool operator that provides mining payments — denying that person input tax credits on property or services acquired for consumption, use or supply in the course of or in connection with providing those mining payments. The section is an Excise Tax Act provision and does not turn on the income tax hobby-versus-business distinction; it applies to the mining activity regardless of whether the miner is a GST/HST registrant, an individual, a sole proprietor or a corporation. It also does not govern income tax treatment: mining receipts may still be income or on account of capital under the Income Tax Act notwithstanding that no GST/HST supply is deemed to occur. Subsections (2) to (4) do not apply to the extent s. 188.2(5) is satisfied — that is, to the extent the mining activity is performed by a particular person for another person where (a) the identity of the other person is known to the particular person; (b) where the mining activity is in respect of a mining group that includes the particular person, the other person is not a mining group operator in respect of that group; and (c) where the other person is a non-resident not dealing at arm's length with the particular person, each property or service received by the other person as a consequence of the mining activity is supplied, or used or consumed in making a supply, to one or more persons each of whom is identified, deals at arm's length with the other person, and is not a mining group operator of a mining group that includes the other person. Where (5) is met, ordinary Part IX rules govern instead.
- Common mistake
- The costliest error is on inputs, not outputs: miners registering for GST/HST and claiming input tax credits on electricity, ASIC hardware, hosting and facility costs. Subsections 188.2(2) and (3) deem those acquisitions and uses to be otherwise than in the course of commercial activities, so the ITCs are not available in respect of mining activities. Miners frequently notice the "no tax on the reward" half of the regime and miss the "no ITCs on the inputs" half. The date error compounds it. Because the enacting Act received royal assent June 22, 2023, filers assume the rules bite from mid-2023. S.C. 2023, c. 26, s. 118(2) deems them in force February 5, 2022, so reporting periods back to that date were on the new footing when filed — a retroactive reach that catches returns prepared before the legislation existed. The only carve-out runs the other way and favours the payer: para. (4)(c) does not apply to property or services acquired, imported or brought into a participating province before February 6, 2022. On the output side, two opposite errors circulate. Some miners charge or self-assess GST/HST on pool payouts or block rewards on the theory that they are paid for a service. Others treat mining receipts as zero-rated exports to a foreign pool — zero-rating presupposes a supply, and where (4)(a) applies there is deemed to be none, so the export analysis is not reached. That second point has a real exception: where s. 188.2(5) switches subsections (2) to (4) off, there is a supply again and ordinary place-of-supply and zero-rating analysis becomes live. Treating "no supply" as universal is itself a mistake. Operator-side, pool and mining-group operators overlook that para. (4)(c) denies them ITCs on inputs referable to providing mining payments — a restriction distinct from, and additional to, the (2)/(3) restrictions.
- Where it is genuinely unsettled
- Two things are genuinely unsettled and neither can be resolved from the statute alone. First, whether a specific receipt is a "mining payment" received "in respect of a mining activity" — as opposed to consideration for a distinct, separately identifiable supply such as hosting, colocation, managed services, firmware or repair work — is a characterisation question turning on the actual contracts and the substance of the arrangement. Mining operations that also sell hosting or services to third parties will have receipts on both sides of the line, and apportionment between them is fact-driven. Second, the s. 188.2(5) exception is drafted around identifiability of the counterparty, mining-group-operator status, and, for non-arm's-length non-residents, the onward-supply chain. Whether a given pool or hosting structure falls inside or outside it depends on how the pool is contractually organised and on facts the miner may not control or even know — notably whether the pool operator is a "mining group operator" in respect of a group that includes the miner, and the residency and arm's-length status of counterparties. Common pooled-mining arrangements were not obviously drafted with these categories in mind. The definition of "cryptoasset" excludes "prescribed property"; no regulation prescribing property for this purpose was located, but that carve-out is a live mechanism for future narrowing. No published CRA interpretation, memorandum, notice or folio applying s. 188.2 to concrete pool or hosting structures was located. That absence matters: the statutory text is clear, but its administration against real mining arrangements is untested in published guidance, and there is no located case law. Anyone with mining receipts, ITC claims filed since February 5, 2022, or a mixed mining-and-services business should have the characterisation and the (5) analysis reviewed by a GST/HST specialist practitioner rather than relying on a general summary.
GST/HST: mining activity deemed not a commercial activity (ITC denial on hardware, imports and electricity) high confidence
- The rule
- ETA s. 188.2(2) provides that, for the purposes of Part IX, "to the extent that a person acquires, imports or brings into a participating province property or a service for consumption, use or supply in the course of, or in connection with, mining activities, the person is deemed to have acquired, imported or brought into the participating province, as the case may be, the property or service for consumption, use or supply otherwise than in the course of commercial activities of the person." Subsection 188.2(3) reaches the same deemed result on the use side, but is triggered by different acts — it applies where "a person consumes, uses or supplies property or a service in the course of, or in connection with, mining activities," and deems that consumption, use or supply "to be otherwise than in the course of commercial activities of the person." Only s. 188.2(2) carries the import wording; s. 188.2(3) does not. The mechanical consequence runs through the ITC formula. Section 169(1) computes an input tax credit as A x B, where B is the extent (expressed as a percentage) to which the person acquired or imported the property or service, or brought it into a participating province, for consumption, use or supply in the course of commercial activities of the person. Where the s. 188.2(2) deeming applies, that extent is deemed to be otherwise than commercial, so element B is nil for the inputs concerned and no ITC is computed on them. Because s. 188.2(2) expressly names property "imported or brought into a participating province," the deeming reaches Division III tax paid on imported hardware under s. 212 as well as GST/HST on domestically acquired equipment, electrical work and power. "Mining activity" is defined in s. 188.2(1) as an activity of: (a) validating transactions in respect of a cryptoasset and adding them to a publicly distributed ledger on which the cryptoasset exists at a digital address; (b) maintaining and permitting access to such a ledger; or (c) allowing computing resources to be used for the purpose of, or in connection with, performing activities described in (a) or (b). "Cryptoasset" is defined as property (other than prescribed property) that is a digital representation of value existing only at a digital address of a publicly distributed ledger. Related and often read together: s. 188.2(4) deems the provision of a mining activity not to be a supply and the provision of a mining payment not to be a supply, so mining rewards are outside the supply/consideration framework rather than being zero-rated or exempt. Effective date: s. 188.2 was enacted retroactively and is deemed to have come into force on February 5, 2022.
- Authority
- Excise Tax Act, R.S.C. 1985, c. E-15, Part IX: s. 188.2(1) (definitions of "cryptoasset", "mining activity", "mining group", "mining group operator", "mining payment"); s. 188.2(2) (acquisition, importation or bringing in); s. 188.2(3) (consumption, use or supply); s. 188.2(4) (mining payments); s. 188.2(5) (exception). Interacting provisions: s. 169(1) (general ITC rule and A x B formula, element B extent-of-commercial-use percentage); s. 123(1) (definitions of "commercial activity" and "person"); s. 212 (Division III tax on imported goods). Enacting instrument: Budget Implementation Act, 2023, No. 1, S.C. 2023, c. 26, s. 118 (royal assent June 22, 2023). Application provision, s. 118(2): subsection (1) "is deemed to have come into force on February 5, 2022 except that, in determining an input tax credit of a person, paragraph 188.2(4)(c) of the Act, as enacted by subsection (1), does not apply in respect of property or a service acquired, imported or brought into a participating province before February 6, 2022." The measure was first released as draft legislation with the February 4, 2022 Department of Finance announcement; the February 5, 2022 date in the statute is the operative one.
- Who it applies to
- The deeming is input-linked and activity-linked rather than person-linked: it operates to the extent property or a service is acquired, imported, brought into a participating province, consumed, used or supplied in the course of or in connection with mining activities. Within that scope it applies to any "person" as defined in ETA s. 123(1) — an individual, partnership, corporation, estate of a deceased individual, trust, or a society, union, club, association, commission or other organization. The text of s. 188.2 contains no dollar threshold, no scale or volume test, and no carve-out for small, casual or non-commercial operators, and the deeming does not turn on whether the person is a GST/HST registrant. Paragraph (c) of the "mining activity" definition extends the concept to allowing computing resources to be used for or in connection with someone else's validation or ledger-maintenance activity, so pure compute contribution is within the definition. The provision operates only for the purposes of Part IX of the Excise Tax Act. It does not apply to the extent the s. 188.2(5) exception is met — broadly, where the mining activity is performed by a particular person for another person whose identity is known to the particular person, subject to conditions about mining group operators and, for non-arm's-length non-residents, about onward supply to identified arm's-length persons (analysed in a separate row). It also has no application to income tax characterisation, to provincial retail sales taxes, or to any tax outside Part IX.
- Common mistake
- Registering for GST/HST specifically in order to recover the GST/HST paid on ASIC purchases, imports, PSUs, electrical work and hydro bills for self-mining, and continuing to file returns claiming those ITCs. This approach was widely described before the February 4, 2022 announcement and a large volume of Canadian crypto-tax content published since still presents it as available, without noting that s. 188.2 was enacted in June 2023 with retroactive effect to February 5, 2022. Publication date is not a reliable filter here, because content written after mid-2023 that was not revised still repeats the old position. The second and more persistent error is treating the income tax characterisation as controlling. A miner who correctly concludes on the facts that they are carrying on a business for income tax purposes frequently assumes that this makes mining a "commercial activity" for GST/HST. These are separate statutory concepts in separate statutes, and s. 188.2 deems the mining inputs to be outside commercial activities for Part IX purposes regardless of how the activity is characterised for income tax. The reverse assumption — that s. 188.2 says something about whether mining hardware or power is deductible or depreciable for income tax — is equally wrong; s. 188.2 is silent on income tax. A third error is reading the s. 188.2(5) exception as a general escape hatch. It is drafted around mining performed for another identified person and is subject to further conditions; it is not a provision about the scale or seriousness of one's own self-mining.
- Where it is genuinely unsettled
- Both s. 188.2(2) and the s. 188.2(5) exception are expressly limited by "to the extent that," so a mixed-use operation — for example a facility that both self-mines and provides taxable hosting, colocation or repair services — involves an apportionment between deemed-non-commercial and genuinely commercial use. How that apportionment is properly measured on particular facts is not resolved by the statutory text, and I was not able to confirm from a primary source whether the CRA has published administrative guidance addressing it: canada.ca returned HTTP 403 to every fetch attempted for this review, so the absence of CRA guidance is unverified and should not be assumed either way. Anyone relying on this row should check current CRA publications directly. Whether a given arrangement is self-mining, a taxable supply of a service to an identified customer, or a mining group arrangement engaging the s. 188.2(5) conditions is itself fact-dependent, and s. 188.2(5) layers in further tests — knowledge of the other person's identity, mining group operator status, and for non-arm's-length non-residents a look-through to onward supply to identified arm's-length persons. That analysis is exactly the kind that requires a GST/HST practitioner on the actual contracts and facts, not a reference table. The retroactive February 5, 2022 application date means the provision reaches reporting periods that were filed, in many cases, before the enacting legislation existed. What follows from that for any particular filing history is a question for a practitioner and is not something this row can state. Separately, "commercial activity" in s. 123(1) already excludes a business carried on without a reasonable expectation of profit by an individual, personal trust, or partnership all of whose members are individuals — a fact-dependent test in its own right. Section 188.2 makes that inquiry largely academic for mining inputs, since the deeming applies whether or not the reasonable-expectation-of-profit threshold would have been met. The business-versus-hobby question therefore has a genuinely different answer in GST/HST than in income tax, and it is not resolved for GST/HST purposes by resolving it for income tax purposes.
The s. 188.2(5) exception — mining performed for an identifiable person medium confidence
- The rule
- ETA s. 188.2(5) provides that subsections 188.2(2) to (4) do not apply in respect of a mining activity to the extent that the mining activity is performed by a particular person for another person if: (a) the identity of the other person is known to the particular person; (b) where the mining activity is in respect of a mining group that includes the particular person, the other person is not a mining group operator in respect of the mining group; and (c) where the other person is a non-resident person and is not dealing at arm's length with the particular person, each property or service — being property or a service received by the other person FROM THE PARTICULAR PERSON as a consequence of the performance of the mining activity — is supplied, or is used or consumed in the course of making a supply, by the other person to one or more persons each of which (i) is a person whose identity is known to the other person, (ii) deals at arm's length with the other person, and (iii) is not a mining group operator in respect of a mining group that includes the other person IF THE MINING ACTIVITY IS IN RESPECT OF THAT MINING GROUP. The disapplied provisions are the ones that otherwise deem inputs to be acquired otherwise than in the course of commercial activities (188.2(2)), deem consumption, use or supply in connection with mining activities to be otherwise than in the course of commercial activities (188.2(3)), and deem the mining activity and the mining payment not to be supplies while denying the payer an ITC (188.2(4)). Where s. 188.2(5) is engaged, those deeming rules are switched off to that extent and the ordinary Part IX rules govern instead — the ordinary rules then determine whether there is a taxable supply made in the course of a commercial activity and the consequent treatment for tax collection, place of supply, zero-rating and input tax credits. Section 188.2(5) does not itself confer commercial-activity status; it removes the statutory bar so the general rules apply. Relevant s. 188.2(1) definitions: "mining group operator", in respect of a mining group, means a person that coordinates, oversees or manages the mining activities of the mining group; "mining group" means a group of persons that, under an agreement, (a) pool property or services for the performance of mining activities, and (b) share mining payments in respect of the mining activities among members of the group.
- Authority
- Excise Tax Act, s. 188.2(5), with the definitions of "cryptoasset", "mining activity", "mining group", "mining group operator" and "mining payment" in s. 188.2(1). Enacted by the Budget Implementation Act, 2023, No. 1, S.C. 2023, c. 26, s. 118(1). EFFECTIVE DATE: s. 118(2) of that Act provides that s. 118(1) "is deemed to have come into force on February 5, 2022", except that in determining a person's input tax credit, para. 188.2(4)(c) does not apply in respect of property or a service acquired, imported or brought into a participating province before February 6, 2022. The retroactive February 5, 2022 application date appears in the enacting statute, not on the consolidated ETA section page. As of the Justice Laws consolidation reviewed (Act current to 2026-05-26, last amended 2026-03-26), the only amendment note carried on s. 188.2 is the original enactment by 2023, c. 26, s. 118 — no subsequent amendment to s. 188.2 was located.
- Who it applies to
- Relevant to any GST/HST registrant or person carrying on mining activities as defined in s. 188.2(1), where mining is said to be performed by one person for a specific identified counterparty — the fact pattern into which hosting, managed-mining and certain contractual arrangements may or may not fall. The conditions are cumulative on their terms: (a) applies in every case; (b) applies only where the mining activity is in respect of a mining group that includes the particular person; (c) applies only where the counterparty is a non-resident who does not deal at arm's length with the particular person. The provision operates "to the extent that" the mining activity is performed for the other person, so it contemplates partial application rather than an all-or-nothing result. It has no application to a person whose activity is not a "mining activity" within s. 188.2(1) in the first place, and the whole of s. 188.2 concerns GST/HST only — it does not govern income tax characterization of mining, which is a separate analysis under the Income Tax Act.
- Common mistake
- Quoting only the "identity is known" limb and stopping there. Summaries routinely reproduce condition (a) and omit (b) and (c) entirely, which makes the exception look far wider than its text. In the standard pool fact pattern, condition (a) can be satisfied — a pool is usually a named, identifiable entity — while condition (b) is the limb that does the work, because it denies the exception where the miner is in a mining group and the counterparty is that group's operator. The mirror-image error is treating any hosting or colocation arrangement as automatically inside the exception without testing (b) and (c) and without establishing that the activity is genuinely performed "for" the identified other person. A third, purely mechanical error is misreading condition (c) by dropping its qualifiers: the property or service must be received by the other person FROM THE PARTICULAR PERSON, limb (i) requires identity known TO THE OTHER PERSON, and limb (iii) is itself conditional on the mining activity being in respect of the mining group in question. A fourth is assuming the rules only bite from the 2023 Royal Assent — they are deemed in force from February 5, 2022.
- Where it is genuinely unsettled
- This is the most fact-dependent provision in the regime and the point at which professional advice stops being optional. Whether a commercial arrangement is a mining activity performed "for" an identifiable other person, whether a "mining group" exists at all, who is its "operator", and whether parties deal at arm's length are all questions of fact and of contractual substance rather than labelling. The pool analysis in particular should not be stated as settled: condition (b) engages only if there is a "mining group", which on the s. 188.2(1) definition requires persons who, UNDER AN AGREEMENT, both pool property or services AND share mining payments among members. Whether a given pool, and a given participant's relationship to it, satisfies that two-part definition is itself a factual question, and different pool payout structures may not answer it the same way. Similarly, "coordinates, oversees or manages" is undefined beyond those words. The phrase "to the extent that" contemplates apportionment, and the statute gives no mechanism for how apportionment is to be measured. No CRA administrative guidance, GST/HST memorandum, technical interpretation or published ruling applying s. 188.2(5) to a real-world hosting or pool structure was located from primary sources, so there is no safe-harbour pattern to point at and no confirmation of how CRA reads any of these terms in practice. The retroactive February 5, 2022 application date means arrangements structured before the 2023 enactment can fall within the provision.
Effective date of Excise Tax Act s. 188.2 (cryptoasset mining) — retroactive to February 5, 2022 high confidence
- The rule
- Excise Tax Act s. 188.2 was enacted by s. 118(1) of the Budget Implementation Act, 2023, No. 1 (S.C. 2023, c. 26), which received Royal Assent on June 22, 2023. The application provision in s. 118(2) reads: "Subsection (1) is deemed to have come into force on February 5, 2022 except that, in determining an input tax credit of a person, paragraph 188.2(4)(c) of the Act, as enacted by subsection (1), does not apply in respect of property or a service acquired, imported or brought into a participating province before February 6, 2022." The deeming rules therefore operate from February 5, 2022 even though the statute was not passed until mid-2023. The single carve-out is narrow and is directed at one paragraph only: 188.2(4)(c), which denies input tax credits to the person who PROVIDES a mining payment (the payer side — typically a mining group operator paying out), not to the miner receiving it. Everything else in s. 188.2 — the s. 188.2(2) rule deeming property or services acquired for mining activities to be acquired otherwise than in the course of commercial activities, the s. 188.2(3) rule deeming consumption, use or supply in the course of mining activities to be otherwise than in commercial activities, and the s. 188.2(4)(a) and (b) rules deeming the provision of a mining activity and the provision of a mining payment not to be supplies — runs from February 5, 2022 with no carve-out at all. Separately, and independently of any date question, the whole of s. 188.2(2) to (4) is subject to the exception in s. 188.2(5), which switches those rules off to the extent a mining activity is performed by a particular person for another person whose identity is known to the particular person, where that other person is not a mining group operator in respect of a mining group that includes the particular person, and where an additional arm's-length condition is met if the other person is a non-resident not dealing at arm's length with the particular person.
- Authority
- Excise Tax Act, s. 188.2 (Cryptoassets), as enacted by S.C. 2023, c. 26, s. 118(1); the application/coming-into-force provision is S.C. 2023, c. 26, s. 118(2). Verified directly against the Justice Laws consolidated text of ETA s. 188.2, whose amendment note reads "2023, c. 26, s. 118", and against the annual statutes text of S.C. 2023, c. 26 where s. 118(2) appears in the wording quoted above. Royal Assent date verified as 2023-06-22 on the Justice Laws landing page for the Act. The February 5, 2022 date is commonly attributed to Department of Finance draft legislative proposals released the previous day (February 4, 2022) — that attribution is plausible and widely repeated, but I could NOT confirm it against a primary Government of Canada source in preparing this entry (the relevant canada.ca news release returned HTTP 403), so it is recorded here as unverified background rather than as authority. Nothing in this entry depends on it: the February 5, 2022 date comes from the statute itself. The consolidated text consulted showed no amendment to s. 188.2 after its 2023 enactment; readers should confirm currency against Justice Laws, which stamps each consolidation with a currency date.
- Who it applies to
- Persons within the scope of ETA s. 188.2 — that is, persons performing mining activities as defined in s. 188.2(1), and, for paragraph 188.2(4)(c) specifically, persons who provide mining payments — for transactions and reporting periods from February 5, 2022 onward. Scope is not universal: s. 188.2(5) removes a mining activity from s. 188.2(2) to (4) to the extent it is performed for another person whose identity is known and who is not a mining group operator in respect of a mining group including the performer (with a further condition where that other person is a non-arm's-length non-resident), so whether a given miner or pool arrangement is caught at all is a separate, fact-driven question from the effective-date question this entry addresses. The February 6, 2022 carve-out is narrow: it preserves the pre-existing position only for the operation of paragraph 188.2(4)(c), and only in respect of property or services acquired, imported or brought into a participating province before that date. It is not a general grandfathering of pre-2022 mining operations, it does not suspend s. 188.2(2), (3), (4)(a) or (4)(b) for any period, and it does not shelter input tax credits denied by the operation of those other provisions.
- Common mistake
- Three errors recur. First, treating the rule as effective from Royal Assent in June 2023, which leaves roughly sixteen months of reporting periods analysed on the wrong basis. Second, relying on Canadian crypto-tax articles, forum posts and firm blogs written before February 2022 — a very large body of still-indexed content — which describe ITC recovery on mining hardware and electricity as straightforwardly available, without any indication that the position changed. Third, and more specific to the text: reading the "before February 6, 2022" language as a general grandfathering of pre-2022 mining activity. It is not. It attaches to paragraph 188.2(4)(c) alone, so the commercial-activity deeming rules in s. 188.2(2) and (3) — the provisions that do the heavy lifting on input tax credit denial for miners — apply from February 5, 2022 with no transitional relief whatsoever. Because the enactment is retroactive, returns filed for 2022 and much of 2023 were filed at a time when the governing statute did not yet exist, yet fall within the deemed period.
- Where it is genuinely unsettled
- Retroactive enactment raises a practical question this entry does not answer: how previously filed returns and previously claimed input tax credits for the deemed period should be dealt with. That is a compliance question with real exposure, and the answer depends on the specific filing history, the reporting periods involved, and normal reassessment periods. It is a matter for a GST/HST practitioner, not something to resolve from a reference page. I did not verify what administrative position, if any, CRA has taken on reassessment, penalty or interest relief for the retroactive window, and no CRA guide, folio or published administrative statement on that point is cited here — the absence of a citation should be read as "not verified", not as "no position exists". Separately, whether a particular operation falls inside or outside s. 188.2 in the first place turns on the s. 188.2(5) conditions — whether the recipient's identity is known, whether that recipient is a mining group operator in respect of a group including the miner, and the arm's-length and residence tests. Pool, hosting and self-mining arrangements differ materially on those facts, and the characterisation is genuinely fact-dependent rather than resolvable by category. The effective date is settled; the question of who is caught by the provision is not, and this entry should not be read as answering it.
GST/HST — "virtual payment instrument" is a financial instrument (ETA s. 123(1)); in force May 18, 2019 medium confidence
- The rule
- ETA s. 123(1) defines "virtual payment instrument" (VPI) as property that is a digital representation of value, that functions as a medium of exchange and that only exists at a digital address of a publicly distributed ledger — other than property that (a) confers a right, whether immediate or future and whether absolute or contingent, to be exchanged or redeemed for, or converted into, money or SPECIFIC property or services, (b) is primarily for use within, or as part of, a gaming platform, an affinity or rewards program or a similar platform or program, or (c) is prescribed property. The statutory word is "specific" property or services, not property or services at large; the carve-out is narrower than a loose paraphrase suggests. Paragraph (f.1) of the s. 123(1) definition of "financial instrument" reads "a virtual payment instrument", so a VPI is a financial instrument. Paragraph (d) of the s. 123(1) definition of "financial service" captures "the issue, granting, allotment, acceptance, endorsement, renewal, processing, variation, transfer of ownership or repayment of a financial instrument" — that is the operative hook for dealings in a VPI — subject to the exclusions in paragraphs (n) through (t). Schedule V, Part VII, s. 1 then reads, verbatim: "A supply of a financial service that is not included in Part IX of Schedule VI." The chain therefore characterises dealings in a qualifying cryptoasset in the financial-services stream rather than the taxable-supply stream. Two structural consequences follow from the Act's design: exempt supplies do not give rise to input tax credit entitlement, and the Schedule VI, Part IX cross-reference matters because financial services falling within that Part are zero-rated rather than exempt — zero-rated supplies do support ITCs. The VPI and financial-instrument amendments are deemed to have come into force on May 18, 2019.
- Authority
- Excise Tax Act, R.S.C. 1985, c. E-15, s. 123(1) — definitions of "virtual payment instrument"; "financial instrument", para. (f.1); and "financial service", para. (d), read with the exclusions in paras. (n)–(t) (note para. (r.5), which expressly preserves "a financial instrument" inside the definition). Schedule V, Part VII, s. 1 (exempt supplies of financial services); Schedule VI, Part IX (zero-rated financial services). Enacting provision: Budget Implementation Act, 2021, No. 1, S.C. 2021, c. 23, s. 100(3) (adds para. (f.1) to "financial instrument") and s. 100(4) (adds the "virtual payment instrument" definition); s. 100(6) provides that "Subsections (3) and (4) are deemed to have come into force on May 18, 2019." All of the foregoing was read directly against the consolidated text on laws-lois.justice.gc.ca. CORRECTION TO A COMMON CITATION: the s. 123(1) definition of "money" was NOT amended to exclude virtual payment instruments — the word "virtual" does not appear in it — so "money" should not be cited as a link in this chain. Separately and for contrast only, ETA s. 188.2 (mining activity in respect of cryptoassets) was added by S.C. 2023, c. 26, s. 118 (Budget Implementation Act, 2023, No. 1, royal assent 2023-06-22).
- Who it applies to
- Any person that supplies or deals in property meeting the VPI definition — registrants and non-registrants alike, incorporated or not. This is a definitional rule of general application, not a mining rule: the GST/HST treatment of mining activity runs through ETA s. 188.2, which is a separate provision with its own later application rule, and the two operate independently of each other. The definition on its own terms describes a permissionless, non-redeemable ledger asset (Bitcoin is the paradigm case on the statutory wording), but the three exclusions carve out a great deal else — tokens conferring a right, immediate or future, absolute or contingent, to be exchanged, redeemed or converted into money or specific property or services; gaming and rewards-program tokens; and prescribed property. Fiat-redeemable stablecoins and much of the NFT and utility-token universe are therefore not obviously inside the definition. Does NOT apply to income tax characterisation: whether cryptoasset activity is business income, property income or capital, and whether it is a business at all, is an entirely separate Income Tax Act analysis governed by different tests.
- Common mistake
- Four recurring errors. (1) Collapsing the two provisions into a single "crypto GST/HST rule" with a single start date — the VPI definition is deemed in force May 18, 2019, whereas ETA s. 188.2 was enacted much later by S.C. 2023, c. 26, s. 118 and carries its own distinct application rule; content that states one date for both is wrong. (2) Treating "exempt" as interchangeable with "zero-rated" — exempt supplies generate no ITC entitlement, zero-rated supplies do, and Schedule V, Part VII, s. 1 is expressly drafted to yield to Schedule VI, Part IX, so the distinction is live rather than academic. (3) Assuming every token is a VPI — the redemption/conversion carve-out is drafted broadly (immediate or future, absolute or contingent) and is easy to trip; the "specific property or services" wording is frequently misquoted as "property or services", which wrongly widens the carve-out. (4) The costly practical one for hardware and equipment vendors: concluding that a sale is GST/HST-free because the customer paid in cryptoasset. Exempt characterisation attaches to the supply of the financial instrument, not to the underlying supply of goods or services being paid for; the taxable sale remains taxable and tax is still calculated on the value of the consideration.
- Where it is genuinely unsettled
- Genuinely unsettled and fact-dependent: whether a particular token satisfies the VPI definition — and in particular whether it falls into the redemption/conversion exclusion in paragraph (a) — is a legal question that turns on the token's actual terms and on who bears what obligation to the holder. Bitcoin is the easy case on the statutory language; almost every other asset requires a token-by-token reading, and a change in a token's redemption terms can change the answer. What was verified here directly from primary text: the VPI definition, "financial instrument" para. (f.1), "financial service" para. (d) and the (n)–(t) exclusion list, Schedule V Part VII s. 1 verbatim, and the enacting and coming-into-force provisions in S.C. 2021, c. 23, s. 100(3), (4) and (6). What was NOT verified in this pass: CRA's administrative guidance on cryptoassets (canada.ca returned HTTP 403 to every request, including GST/HST Notice 324 and the CRA cryptocurrency guide), so nothing in this row rests on CRA guidance; and the specific application date attaching to ETA s. 188.2, which is stated in the companion s. 188.2 row and should be confirmed against the enacting statute before republication. The full paragraph text of Schedule VI, Part IX was also not read end to end, so the zero-rating carve-out is described from the cross-reference in Schedule V, Part VII, s. 1 rather than from Part IX's own conditions. This row describes statutory structure only. It does not determine any particular person's GST/HST status, registration obligation, ITC entitlement or filing position; characterising a specific token or transaction requires a Canadian indirect tax practitioner working from the token's terms and the taxpayer's facts.
GST/HST: effective date of the "virtual payment instrument" rule — May 18, 2019 high confidence
- The rule
- Section 100 of the Budget Implementation Act, 2021, No. 1 (S.C. 2021, c. 23) amended the definitions in s. 123(1) of the Excise Tax Act. Subsection 100(3) adds "a virtual payment instrument" as paragraph (f.1) of the "financial instrument" definition; subsection 100(4) enacts the "virtual payment instrument" definition itself. The coming-into-force subsection, s. 100(6), reads: "Subsections (3) and (4) are deemed to have come into force on May 18, 2019." The enacting Act received Royal Assent on June 29, 2021, so both amendments operate retroactively by just over two years. The date attaches only to subsections (3) and (4): the separate coming-into-force subsection s. 100(5) gives July 1, 2021 for the unrelated amendments in s. 100(1) and (2). The retroactive characterisation does not reach every cryptoasset — the enacted definition covers property that is a digital representation of value, functions as a medium of exchange, and exists only at a digital address of a publicly distributed ledger, but expressly excludes three categories of property (set out under Nuance). The statute states no reason for the retroactive date.
- Authority
- Excise Tax Act, s. 123(1) (definitions of "financial instrument" and "virtual payment instrument"), as amended by S.C. 2021, c. 23, ss. 100(3) and 100(4); coming into force per S.C. 2021, c. 23, s. 100(6). For the contrasting date: Excise Tax Act, s. 188.2, enacted by S.C. 2023, c. 26, s. 118(1), with s. 118(2) deeming it in force February 5, 2022. All wording verified verbatim against Justice Laws Canada consolidations.
- Who it applies to
- A GST/HST rule under the Excise Tax Act. It bears on any person — hobby miner, sole proprietor, corporation, registrant or not — making supplies of, or dealings in, property that meets the statutory "virtual payment instrument" definition, for the period from May 18, 2019 onward. It does not apply to property caught by the definition's exclusions, and it does not govern income tax characterisation, which runs on a separate framework and separate timeline. It is distinct from, and commences earlier than, the February 5, 2022 date governing the s. 188.2 mining deeming rules.
- Common mistake
- Quoting a single effective date for "the Canadian crypto GST/HST rules." Two different rules in two different enacting statutes commence on two different dates — May 18, 2019 for the virtual payment instrument / financial instrument characterisation (S.C. 2021, c. 23), and February 5, 2022 for the s. 188.2 mining deeming rules (S.C. 2023, c. 26) — so content that merges them misstates the position for the roughly 33-month window between those dates. Two related errors are just as common among miners: assuming every token is automatically a "virtual payment instrument" when the definition carries three express carve-outs, and importing the GST/HST characterisation into income tax reporting, where it does not govern. Content written before mid-2021 describing cryptocurrency as having no settled GST/HST characterisation is now stale.
- Where it is genuinely unsettled
- Whether a given token is a "virtual payment instrument" is genuinely fact-dependent and cannot be answered generically. The definition excludes property that (a) confers a right to be exchanged or redeemed for money or specific property or services, or to be converted into money or specific property or services, (b) is primarily for use within, or as part of, a gaming platform, an affinity or rewards program or a similar platform or program, or (c) is prescribed property. Carve-out (a) in particular raises unsettled questions for redeemable and asset-referenced tokens, and carve-out (c) means the scope can shift by regulation. Applying the exclusions to a specific token is a legal characterisation exercise for a practitioner. Separately, both this rule and s. 188.2 are retroactive, which raises questions about reporting periods already filed; the s. 188.2 provision also carries its own limited exception, under which para. 188.2(4)(c) does not apply in determining an input tax credit in respect of property or services acquired, imported, or brought into a participating province before February 6, 2022. How retroactivity interacts with a particular filing history depends on the facts of that history and is a matter for a qualified Canadian tax adviser.
GST/HST registration and the small supplier threshold for cryptoasset mining high confidence
- The rule
- ETA s. 240(1) requires registration by "every person who makes a taxable supply in Canada in the course of a commercial activity engaged in by the person in Canada," except where (a) the person is a small supplier, (b) the person's only commercial activity is making supplies of real property by way of sale otherwise than in the course of a business, or (c) the person is a non-resident who does not carry on any business in Canada. Section 148(1) treats a person as a small supplier throughout a calendar quarter and the following month where the total value of the consideration for taxable supplies made by the person — and by any associate of the person at the beginning of that quarter — inside or outside Canada in the four immediately preceding calendar quarters does not exceed $30,000, or $50,000 where the person is a public service body. The computation excludes supplies of financial services, supplies by way of sale of capital property, and consideration referred to in s. 167.1 attributable to goodwill of a business. Section 148(2) ends small supplier status where the threshold is exceeded within a single calendar quarter. Section 240(3) permits a person not required to register to apply voluntarily where, among other grounds, the person "is engaged in a commercial activity in Canada" (para (a)). Section 188.2 overlays this for cryptoassets. Section 188.2(4)(a) and (b) deem the provision of a mining activity and the provision of a mining payment not to be supplies. Sections 188.2(2) and (3) deem property or services acquired, imported or brought into a participating province for use in mining activities, and property or services consumed, used or supplied in the course of or in connection with mining activities, to be otherwise than in the course of commercial activities of the person. Section 188.2(5) switches that deeming off to the extent the mining activity is performed for another person whose identity is known to the miner, subject to the further conditions in paras (b) (the other person is not a mining group operator of a mining group including the miner) and (c) (an arm's-length and onward-supply condition where the other person is a non-resident not dealing at arm's length). Where the deeming in ss. 188.2(2) to (4) applies, the statutory consequence is that there is no taxable supply capable of triggering s. 240(1), and no consideration for a taxable supply to enter the s. 148 computation.
- Authority
- Excise Tax Act, R.S.C. 1985, c. E-15, ss. 240(1), 240(3)(a), 148(1)–(2), 188.2(1)–(5); "virtual payment instrument" defined in s. 123(1). Section 188.2 was enacted by the Budget Implementation Act, 2023, No. 1, S.C. 2023, c. 26, s. 118, and is deemed to have come into force on February 5, 2022, except that para 188.2(4)(c) does not apply in determining an input tax credit in respect of property or a service acquired, imported or brought into a participating province before February 6, 2022. Text verified against the Justice Canada consolidation current to May 26, 2026 (last amended March 26, 2026). No CRA guide, folio or published administrative guidance was verified for this row; the authority here is statutory only.
- Who it applies to
- Anyone assessing whether a mining operation creates a GST/HST registration obligation, and anyone computing the s. 148 small supplier threshold where mining receipts are present. The s. 188.2 deeming operates on the character of the activity as defined in s. 188.2(1); it does not turn on whether the miner is a hobbyist, sole proprietor or corporation, and it does not import the income-tax business-versus-hobby analysis. Note that the s. 148 threshold aggregates the person's supplies with those of associates, so related entities are not assessed in isolation. Important for mixed operations: a person carrying on both mining and genuinely taxable activities — hardware sales, repair services, hosting arrangements falling within s. 188.2(5), consulting — is making taxable supplies through those other activities, and each is assessed under the ordinary rules on its own footing.
- Common mistake
- A hobbyist or small miner registering voluntarily for the specific purpose of recovering GST/HST on a handful of ASICs and their power bill. Sections 188.2(2) and (3) deem those acquisitions and that use to be otherwise than in the course of commercial activities, and registration status does not displace that deeming. The inverse error occurs at the other end of the scale: an operator with substantial taxable repair, hosting or resale revenue reasoning that because "mining is outside GST/HST" the whole enterprise is, and not registering in respect of the taxable side — where the associates rule in s. 148(1) can also pull related-entity supplies into the threshold. A third and increasingly common error is relying on commentary written before February 5, 2022, or before the June 2023 enactment, which describes mining receipts under the pre-188.2 framework.
- Where it is genuinely unsettled
- Several points here are genuinely fact-dependent or unresolved on the statutory text alone, and warrant a GST/HST practitioner. First, whether a particular hosting or colocation arrangement falls inside s. 188.2(5) is a characterisation question. Supplying rack space, power and cooling may be analysed on ordinary principles as a taxable supply of services or real property rather than as a mining activity performed for a known person, and the three conditions in s. 188.2(5)(a)–(c) each have to be satisfied on the facts. Second, for a mixed operation, how consideration is allocated between mining and non-mining activity, and to what extent inputs are used in each, is a factual determination that drives both the threshold computation and any input tax credit position. Third, s. 240(3)(a) conditions voluntary registration on being "engaged in a commercial activity in Canada," while s. 188.2(3) deems consumption, use and supply in the course of mining activities to be otherwise than in the course of commercial activities. Whether a person whose only activity is deemed mining qualifies under s. 240(3)(a) at all is not settled by the express words of either provision. Fourth, the "mining activity" definition in s. 188.2(1) is drafted broadly — validating transactions and adding them to a publicly distributed ledger, maintaining or permitting access to such a ledger, or allowing computing resources to be used for those purposes — and its application to consensus mechanisms other than proof of work is not addressed expressly in the section. Fifth, this row addresses registration and the threshold only. The GST/HST treatment of a subsequent disposition of a mined cryptoasset runs through separate machinery, including the "virtual payment instrument" definition in s. 123(1) and the financial service rules. Whether a virtual payment instrument is captured by the "financial instrument" definition could not be confirmed from the primary text in the course of preparing this row, and no conclusion on the disposition side is stated here. Finally, because s. 188.2 is deemed in force from February 5, 2022 but was only enacted in June 2023, reporting periods filed in the interval may have been prepared on a different basis; the consequences of that are period-specific.
GST/HST when accepting Bitcoin as payment for taxable goods or services medium confidence
- The rule
- A cryptoasset meeting the s. 123(1) definition of "virtual payment instrument" (VPI) is included in the s. 123(1) definition of "financial instrument" at paragraph (f.1), which reads "a virtual payment instrument". That characterisation governs dealings in the cryptoasset itself. It does not alter the GST/HST status of a separate underlying supply of goods or services for which the cryptoasset is tendered as consideration. Under s. 165(1) tax is calculated "at the rate of 5% on the value of the consideration for the supply", with the provincial component added under s. 165(2) for a supply made in a participating province — the imposition turns on the supply being a taxable supply made in Canada, not on the form of payment received. A VPI is not "money": s. 123(1) defines money by reference to "any currency, cheque, promissory note, letter of credit, draft, traveller's cheque, bill of exchange, postal note, money order, postal remittance and other similar instrument". Consideration tendered in a VPI is therefore non-monetary, and s. 153(1) supplies the valuation rule — where consideration is money the value is the amount of the money, and where it is not money the value is "the fair market value of the consideration or that part at the time the supply was made". The obligation to charge and remit attaches to a person who is a registrant or required to be registered (ss. 240 and 148); the form of consideration does not by itself change that status, since the small-supplier threshold is measured on the value of consideration for taxable supplies.
- Authority
- Excise Tax Act, R.S.C. 1985, c. E-15: s. 123(1) definitions of "money", "virtual payment instrument", "financial instrument" (VPI expressly included at para. (f.1)) and "consideration" ("includes any amount that is payable for a supply by operation of law"); s. 165(1)–(2) (imposition at 5% federal plus the provincial component on the value of the consideration); s. 153(1) (value of consideration — the amount of the money where consideration is money, otherwise the fair market value of the consideration at the time the supply was made). Registration and small-supplier rules at ss. 240 and 148. Distinct from s. 188.2, titled "Cryptoassets" and enacted by S.C. 2023, c. 26, s. 118, which addresses mining activity, mining groups and mining payments. The s. 123(1), s. 153(1) and s. 165 text quoted above was read against the Justice Laws consolidation of the Act; the coming-into-force provisions were not verified in this session.
- Who it applies to
- Any Canadian vendor making a taxable supply of goods or services and accepting Bitcoin or another cryptoasset as consideration, including through a payment processor — directly relevant to a hardware sales or ASIC repair business accepting BTC. The collection and remittance rules bite only where the vendor is a GST/HST registrant or is required to register; an unregistered small supplier is in a different position under ss. 148 and 240. Does not apply to the mining activity regime in s. 188.2, which is a separate set of rules about mining activities, mining groups and mining payments rather than about payment acceptance. Does not address the income tax treatment of any gain or loss on cryptoassets subsequently held, which is governed by the Income Tax Act and is outside the scope of this row.
- Common mistake
- Believing that accepting payment in Bitcoin takes the sale outside GST/HST, or that it converts the transaction into an exempt financial-services transaction. The financial-instrument characterisation attaches to the cryptoasset leg, not to the goods or services being sold — the underlying taxable supply remains a taxable supply. A second and very common error is failing to establish and contemporaneously document a fair market value for the consideration at the time the supply was made, which is the figure s. 153(1) makes the tax base for non-monetary consideration; reconstructing it later from an arbitrary exchange rate source is where records fail on audit. A third is treating Bitcoin as though it were foreign currency and reaching for the currency-conversion machinery in s. 159 — that provision is framed around currency, and because a VPI is not "money" the s. 153(1) fair-market-value rule is the operative valuation provision instead. A fourth is assuming crypto-denominated sales do not count toward the small-supplier threshold.
- Where it is genuinely unsettled
- Not every cryptoasset is a virtual payment instrument, and the row should not be read as though the label were automatic. The s. 123(1) definition carves out property that confers a right to be exchanged or redeemed for money or specific property or services, property primarily for use within or as part of a gaming platform, and prescribed property. Bitcoin sits squarely inside the definition; certain stablecoins, utility tokens and redeemable tokens may fall outside it, and that characterisation is genuinely fact-dependent on the token's terms. Effective dates are the weakest point here: the VPI definition and para. (f.1) were added by budget implementation legislation and s. 188.2 by S.C. 2023, c. 26, s. 118, and both carry retroactive application rules, but I could not verify those coming-into-force dates against a primary source in this session — the relevant CRA guidance page returned HTTP 403 and search was unavailable. Anyone relying on this analysis for a historical reporting period must confirm the coming-into-force provisions directly before acting. Relatedly, the reason the payment leg does not attract tax in its own right runs through the "financial service" definition in s. 123(1) and the exemption in Schedule V, Part VII; I confirmed para. (f.1) of "financial instrument" but did not read those two provisions end to end. CRA administrative guidance on valuation and documentation for crypto-denominated sales is thin — which rate source, at what timestamp, and what records suffice are not addressed with the specificity available for foreign-currency transactions. Payment-processor arrangements are fact-dependent: whether the vendor is properly treated as receiving cryptoasset or fiat consideration depends on the contractual terms and who bears price risk between quotation and settlement, which changes the s. 153(1) analysis. Whether a supply is made in Canada and in which participating province remains a separate place-of-supply question untouched by the form of payment. These are areas for a GST/HST practitioner, not for self-assessment from a reference table.
Scope, method, and what we deliberately did not publish
This page is GST/HST only, and that narrowing was a decision rather than an oversight. We researched the income-tax side in the same pass — business characterisation, timing and valuation of mined coins, adjusted cost base, inventory versus capital, capital cost allowance on hardware, records retention, T1135 — and then did not publish it, because CRA reorganised its crypto-asset guidance into new subpages in late 2025 and those administrative pages could not be reached for independent verification while this page was being written. Tax content that sounds authoritative and is stale causes real financial harm, so it waits. The part of the income-tax side that rests on STATUTE rather than CRA policy — business characterisation, CCA Class 50, adjusted cost base, records retention — is published separately in income tax statutes for Canadian Bitcoin miners.
What IS here rests on statute rather than administrative opinion. Every rule names an Excise Tax Act provision, and the two load-bearing ones were read directly from the Justice Laws Website during editing: s. 188.2 (the mining-activity deeming rules and the s. 188.2(5) exception) and the s. 123(1) definitions of “virtual payment instrument” and “financial instrument”. Accounting-firm commentary was expressly barred as authority throughout — useful for finding a lead, never for citing.
One caveat on rates and thresholds: statutory rules change and are amended retroactively more often than people expect. Check the current provision text before relying on any figure here.
Related: income tax statutes for miners · Canada sales tax by province · ASIC import cost calculator · provincial mining rules · electricity rates for miners · ROI calculator
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