The short answer
You can claim an input tax credit for GST paid on imported goods only if you are the de facto importer: broadly, the person who caused the goods to be brought into Canada, for consumption, use or supply in your own commercial activity. Who is named as importer of record on the customs document is a separate question.
Most of the time the two are the same person and the claim is straightforward. When they are not, the claim is either unsupported or belongs to somebody else. And even when you are the de facto importer, the credit is proportional, not all-or-nothing: it tracks the extent to which the goods are used in your commercial activities.
One thing to fix in your head before you start reconciling: commercial goods entering Canada attract the 5% federal GST at the border, not 13% HST. If you are looking for 13% on a customs document you will not find it.
The rule, and the word that does the work
The entitlement comes from subsection 169(1) of the Excise Tax Act. The CRA summarises it this way: a registrant is entitled to an ITC for tax on the importation of goods paid or payable by the registrant, if the registrant imports the goods for consumption, use or supply in the course of its commercial activities.
Two things get lost in that summary and both matter. The statute covers tax that becomes payable or is paid without having become payable. And the credit is computed as a formula: the tax multiplied by the extent, expressed as a percentage, to which you imported the goods for use in commercial activities. Mixed use gives a partial credit. Reading the rule as a yes-or-no question is the first mistake.
The second is reading it as a question about who paid. It isn't. It turns on who imports, and the CRA has a specific meaning for that word. Its policy statement P-125 puts it this way:
"Subject to the special provisions discussed below, it is only the de facto importer who may be considered to have imported the goods for consumption, use or supply in the course of its commercial activities."
The de facto importer is, in the CRA's words, "essentially the person who causes the goods to be imported." Note the hedge: this is a description, not a statutory definition. The CRA adds that a key factor in determining who the de facto importer is, is the place of supply of the goods. Where title passed matters, not just who arranged the shipping. And critically, the de facto importer need not be the customs importer of record. The name on the customs paperwork and the person entitled to the credit are two separate determinations, made under two different bodies of law, and nothing forces them onto the same party.
Excise Tax Act s.169(1); CRA Policy Statement P-125 (1 June 2007).For most Ontario importers buying their own stock from an overseas supplier and selling it here, this is a distinction without a difference. You caused the goods to come in, title passed to you outside Canada, you sell them here, you are both the de facto importer and the importer of record, and the credit is yours. The trouble starts at the edges, and the edges are more common than people expect.
Four ways this goes wrong in small-business books
Ordered by how often they turn up, not by how much they cost. Two create exposure. Two quietly cost money. It is entirely normal to find more than one in the same set of books, in different months, depending on who was doing the coding at the time.
01 The broker is importer of record and you never got the paperwork Exposure
Where a third party acts as importer of record and pays the tax at the border, the CRA does allow the de facto importer to recover it. Two things have to be true. The de facto importer "will be considered to have paid the tax on the importation if evidence is maintained that the importer of record paid the tax on behalf of the de facto importer," and it "will be required to obtain a copy of the import documentation from the importer of record in order to satisfy the documentary requirements."
In practice a broker's summary invoice is thin support on its own. It is the broker's billing document, not the customs accounting document, and a reviewer will ask for the latter. If the only thing in your file is the broker's monthly statement, the claim may well be valid, but you are relying on a document that was never designed to prove it.
02 You are importer of record for goods that were never yours Exposure
This shows up with drop-shipped goods, stock brought in for a related company, and shipments cleared under your account as a favour to a customer or a supplier. You paid the tax, so it feels like yours to claim.
But if you did not cause the goods to be imported for use or supply in your own commercial activity, you are not the de facto importer. Several provisions create routes through some of these arrangements: section 178.8 where goods were supplied to you outside Canada but another person physically imported and accounted for them, section 180 where an unregistered non-resident paid the tax, and section 179 for drop-shipments specifically. All three are genuinely intricate, and this is the point at which the answer stops being a bookkeeping question.
03 The border GST is buried in an expense account Costs you money
The most common of the four, and the one that costs rather than risks. A broker's invoice usually bundles several things: brokerage fees, duty, disbursements, and the GST the broker advanced at the border on your behalf. Coded as a single line to Customs & Duty, Freight, or worse, Miscellaneous, the recoverable GST disappears into an expense account.
Nothing is wrong on the return. The tax simply never gets claimed. Across a couple of years of regular importing this is the error that quietly adds up to real money, and it is invisible unless somebody goes looking line by line.
04 The same GST claimed twice Exposure
The mirror image of the one above. The GST appears once on the customs accounting document, and again on the broker's invoice, restated as a disbursement they are recovering from you. Claim from both documents and the same tax has been claimed twice.
This one is easy to create and hard to spot, because both entries look correct in isolation. It is the pattern most likely to surface on review, and the practical fix is a coding convention rather than a one-time correction: decide which document is the claiming document, and stay consistent.
What has to be in the file, and when
There are two different evidence questions here and conflating them is a common source of confusion.
For the tax you paid at the border
Tax on importation is not a supply. There is no supplier and no supplier registration number, so the tiered invoice rules below do not govern it. What governs it is subsection 169(4): a registrant may not claim an ITC unless, before filing the return in which the credit is claimed, it has obtained evidence sufficient to determine the amount of the credit. For border tax, that evidence is the customs accounting document.
The timing in that provision is not decorative. Assembling the file after the CRA asks is too late as a matter of law. If a broker cleared the goods, that document sits in their system by default rather than yours, which is exactly how pattern 01 above happens.
Under the CBSA's CARM system, the Commercial Accounting Declaration has replaced the old B3 coding form and B2 adjustment request. CARM became the official system of record for imposing and levying duties and taxes on 21 October 2024, so records spanning that transition will hold both formats.
For everything the broker actually charged you
The broker's own fees are a supply made to you, and those follow the tiered rules in the Input Tax Credit Information (GST/HST) Regulations. Each tier includes everything required by the tier below it. The amount tested is the total shown on the document, tax included, not the pre-tax consideration.
| Document total, incl. tax | What the supporting document must show |
|---|---|
| Under $100 | The supplier's or intermediary's name, or the name they do business under. The invoice date, or where no invoice was issued, the date the tax became payable. The total amount paid or payable. |
| $100 to under $500 | Everything above, plus the registration number assigned to the supplier or intermediary under section 241 of the Act, and the amount of tax, either stated separately or shown as tax-included together with the applicable rate. Where the document covers supplies of differing status, the status of each must be identifiable. |
| $500 and over | Everything above, plus the recipient's name, trading name, or the name of the recipient's duly authorised agent or representative. The terms of payment. And a description of each supply sufficient to identify it. |
Worth knowing if you are checking this yourself. These thresholds were $30 and $150 until 20 April 2021. They are now $100 and $500. CRA's GST/HST Memorandum 8-4, which is still the top result for most searches on this subject, was published in August 2012 and still prints the old figures.
It is a real CRA publication, on canada.ca, and it is out of date. That is a fair illustration of why a source being authoritative and a source being current are two different things, and why anything you get from an AI assistant on a question like this needs its date checked before you act on it.
One more thing on evidence. The Regulations do treat a book or ledger of account, and records held in a computerised system, as supporting documentation. So a ledger entry is not disqualified. But section 169(4) asks for evidence sufficient to determine the amount of the credit, and a general ledger line with nothing behind it does not do that. A tidy set of books with an empty document file is not the same thing as a supported claim.
How far back you can fix it
An unclaimed ITC is not automatically lost. For most registrants the credit must be claimed by the due date of the return for the last reporting period ending within four years after the end of the reporting period in which the tax became payable, or was paid without having become payable. In practice that is slightly more than four years, and how much more depends on your filing frequency.
For a monthly or quarterly filer in 2026 that generally reaches back into 2022. Annual filers should check their own dates rather than assume.
The window narrows to two years for what the Act calls a specified person. That means a listed financial institution, of any size, or a person whose threshold amounts exceed $6 million in both the fiscal year containing the reporting period and the preceding one. Even above $6 million, a person is not a specified person if all or substantially all of its supplies in either of the two preceding fiscal years were taxable, which is why most ordinary trading businesses stay on the four-year rule regardless of size. Charities are also outside it.
CRA GST/HST Memorandum 8-1, General Eligibility Rules.Checking your own records this afternoon
You do not need software or an advisor to find out whether the common coding failures are present. You need one broker invoice and ten minutes.
- Pull the most recent broker invoice and find every separate charge on it. Fees, duty, disbursements, GST. Four different things.
- Find the same transaction in your accounting software. If the whole invoice went to one account as one number, you have pattern 03.
- Search your GST/HST paid account for that shipment. If the amount appears twice, once from the customs document and once from the broker invoice, you have pattern 04.
- Ask who is named as importer of record. If it is not your business, find out whether you hold copies of the import documentation, and whether anything records that the tax was paid on your behalf.
- Repeat on one invoice from twelve months ago. Coding conventions drift when the person doing the books changes, and the older file is usually the more honest test.
If all five come back clean, the routine problems are not present in your books. That is a real result and worth having. It does not settle entitlement on any particular shipment, which turns on facts a checklist cannot see, but it does mean the common errors are not costing you money.
Where this stops being a bookkeeping question
Everything above is general information about how the rules are structured, not advice about your situation. Whether a specific shipment gives you an ITC, and for how much, depends on facts this article cannot see. The arrangements in pattern 02 in particular are exactly the kind of thing that needs a professional opinion rather than a confident guess.
Correcting prior returns, deciding whether to amend or adjust, and anything touching CRA correspondence belongs with a CPA or a commodity tax specialist. Keplar does not do that work and does not replace the people who do.
Sources
- Input Tax Credit Information (GST/HST) Regulations, SOR/91-45 — s.2 and s.3. Thresholds as amended by S.C. 2024, c.15, s.142, effective 20 April 2021.
- CRA Policy Statement P-125, Input Tax Credit Entitlement for Tax on Imported Goods — dated 1 June 2007.
- CRA GST/HST Memorandum 8-1, General Eligibility Rules — time limits and the specified person definition. Last revised 20 July 2023.
- CRA GST/HST Memorandum 8-4, Documentary Requirements for Claiming Input Tax Credits — published August 2012; its $30 and $150 thresholds are superseded. Listed for completeness, not relied on.
- CBSA, CARM — the Commercial Accounting Declaration, and the 21 October 2024 system-of-record date.