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GST/HST · Importers

What is actually recoverable on a customs broker's invoice

Four different kinds of money arrive on one document, and they carry three different tax treatments. Coding them as one line is the most expensive habit in small-importer bookkeeping, and inventing a credit on the freight is the most common way to get it wrong in the other direction.

26 August 2026 10 min read Ontario, Canada

The short answer

A typical inbound broker invoice mixes four things. They are not interchangeable:

  • Customs duty. Never recoverable as an input tax credit. It is not GST/HST, so there is no credit to claim. It is a cost of the goods.
  • GST advanced at the border. 5% federal GST, recoverable if you are the de facto importer, and only to the extent the goods are used in your commercial activities.
  • The broker's own service fee. A taxable supply made to you, at 13% HST in Ontario. Recoverable in the ordinary way. Note that this is a different rate from the 5% on the goods, on the same invoice.
  • International freight. Usually zero-rated, so there is usually no tax on it to claim. If your books show an ITC against the international leg, something has gone wrong.

Zero-rated means the supply is taxable but the rate is 0%. Nothing was charged, so nothing can be recovered. It is not the same as exempt: the buyer sees no tax either way, but a zero-rated supplier keeps its own input tax credits and an exempt one does not.

Duty is not a tax you can claim

This is the single most common misconception, and it is worth being blunt about. Customs duty is imposed under the Customs Tariff. Input tax credits exist under the Excise Tax Act and are available only for GST/HST. Duty is not GST/HST, so no amount of correct bookkeeping turns it into a credit.

Duty is a real cost, and it belongs in the cost of the goods, which usually means inventory and then cost of sales. Businesses that push duty into a tax account are not just misfiling a credit, they are also understating what their stock actually cost them, which quietly distorts margin on every subsequent report.

Duty makes your goods more expensive. It does not make your tax bill smaller.

It makes them more expensive twice over, in fact. Under subsection 215(1) of the Excise Tax Act, the value the 5% is calculated on is the value for duty plus the duty itself, and any other Customs Tariff, SIMA or excise amounts. That is why the GST figure on a customs document never equals 5% of your supplier's invoice, and why a reconciliation built on the assumption that it should will never balance.

The Ontario 8% nobody self-assesses

Commercial goods entering Canada are assessed the 5% federal GST at the border. Ontario's 8% provincial part is not collected there, which is where the trouble starts, because for some importers it is still owed.

Section 220.07 imposes the provincial part on goods brought into a participating province from outside Canada. Subsection 220.07(2) carves out goods brought in by a registrant for consumption, use or supply exclusively in the course of commercial activities, and that carve-out is why most importers never think about it. But exclusively is doing real work in that sentence.

If any part of what you do is exempt, this applies to you. A medical or dental practice, a residential landlord, a financial services firm, a mixed-use business: the exclusivity condition is not met, and the Ontario 8% on imported goods is yours to self-assess. Nobody invoices you for it. It does not appear on the broker's document. It is a liability rather than a missed credit, which makes it the worst direction to be wrong in.

Imported vehicles are outside the carve-out in every case. A specified motor vehicle brought into Ontario carries the 8% whether the use is commercial or not.

Excise Tax Act ss. 212, 212.1(3), 215(1), 220.07.

The freight trap: zero-rated is not a credit

Freight transportation is where invented credits come from. The rules are specific and they mostly run in the importer's favour, which is the confusing part.

A freight transportation service is zero-rated when the movement is international: from a place in Canada to a place outside Canada where the charge is $5 or more, from outside Canada to a Canadian destination, or from a place outside Canada to another place outside Canada. Purely domestic movement, where origin and destination are both in Canada, is taxable at 5% GST or the relevant HST rate depending on the destination province.

So on an inbound shipment from Shenzhen or Rotterdam, the international carriage is zero-rated. The carrier charges nothing in tax, correctly. There is no credit to claim and there never was.

CRA, GST/HST information for freight carriers; Excise Tax Act, Schedule VI, Part VII.

The domestic leg, which is where it gets interesting

Once the container lands, something still has to move it from the port to your warehouse. That leg looks purely domestic, so the instinct is to treat it as taxable and claim the GST.

Often that instinct is wrong, in your favour. Under section 10 of Part VII of Schedule VI, the domestic portion is also zero-rated where two conditions hold: the service is part of a continuous freight movement from an origin outside Canada to a destination in Canada, and the supplier maintains documentary evidence satisfactory to the Minister that this is so. The CRA gives an air waybill showing origin and destination as an example.

Everything then turns on the statutory definition, and it is longer than the phrase suggests. A continuous freight movement is the transportation of goods by one or more carriers to a destination specified by the shipper, where all the freight transportation services supplied by the carriers are supplied as a consequence of instructions given by the shipper. Two defined terms tighten it further: destination means the place the shipper specified at which possession passes to the consignee, and a shipper cannot be one of the carriers.

Two consequences follow, and they are the practical heart of this.

So when a domestic drayage invoice on an inbound container arrives with tax on it, check your own booking before you call the carrier. The carrier can tell you what evidence it holds. It cannot tell you whether you severed the chain by booking that leg separately, and asking it to zero-rate something it cannot lawfully zero-rate helps nobody.

Excise Tax Act, Schedule VI, Part VII, ss.1(1) and 10. CRA GST/HST Memorandum 28-2, Freight Transportation Services (revised 21 September 2017).

Outbound, the paperwork obligation reverses

Worth knowing if you also export. On the mirror case, a domestic leg feeding an export, section 7 requires you, as shipper, to give the carrier a declaration in prescribed form stating that the goods are being shipped for export and that the service forms part of a continuous outbound freight movement. The goods must actually be exported and the consideration must be $5 or more.

Inbound, the carrier carries the paperwork. Outbound, you do. An exporter who assumes the inbound rule runs both ways simply never files the declaration and pays 13% on pre-export domestic legs that did not have to bear it.

The practical rule. If your accounting software shows recoverable tax against an international freight line, do not assume you found money. Assume you found a coding error, and check the carrier's invoice for what tax was actually charged.

A zero-rated supply that has been coded as taxable creates a credit out of nothing. It is the mirror image of burying recoverable GST in an expense account, and it is the version that gets assessed.

Reading the invoice line by line

Line on the invoiceWhat it isRecoverable?
Customs duty Levied under the Customs Tariff. Not GST/HST. No — cost of goods
GST at import 5% federal GST under s.212, on the value for duty plus the duty itself. Yes — if you are the de facto importer, to the extent of commercial use
Ontario 8% Not charged at the border. Self-assessed under s.220.07 unless your use is exclusively commercial. Liability — not a credit
Brokerage fee The broker's own service, supplied to you in Canada. 13% HST in Ontario, because place of supply for a service follows your business address. Yes — at a different rate from the line above
RPP / portal fees New since CARM. Financial security administration and portal handling. The broker's own taxable service. Yes — these are fees, not disbursements
International freight Zero-rated international transportation service. No tax charged — nothing to recover
Domestic drayage Zero-rated if part of a continuous inbound movement with carrier evidence. Otherwise taxable. Depends — check what was charged
Disbursements Amounts the broker advanced to CBSA on your behalf and is recharging. Follows whatever it was — see below

That last row is the one to be careful with, because "disbursements" is a billing convention rather than a tax category. The line usually recovers duty and border GST the broker fronted for you. Those two amounts keep their own character: the duty stays non-recoverable, the GST stays recoverable on the strength of the customs accounting document. What matters is not to treat the disbursement total as though it were consideration for a service the broker supplied, and not to claim the GST twice, once from the customs document and once from this line.

Broker invoice formats vary more than they should. If yours does not clearly separate duty, border GST, fees, and the tax on those fees, that is a reasonable thing to ask them to itemise. Most will, and the request is a normal one.

The document behind the border GST is the Commercial Accounting Declaration, which replaced the old B3 when CARM became CBSA's system of record on 21 October 2024. If your 2026 invoices carry line items that were not there in 2023, that is usually why: since the transition period closed on 20 May 2025 importers post their own financial security in the CARM portal rather than relying on the broker's bond, and the administration of that shows up as a fee. It is a fee, so it is taxable and recoverable. It is not a disbursement.

One more case worth recognising: sometimes there is no GST line because none was owed. Schedule VII lists non-taxable importations, including goods whose supply would be zero-rated domestically and courier shipments from the United States or Mexico valued at $40 or less. A small courier entry with no tax on it is not necessarily a broker error.

Checking one invoice

Where this stops being a bookkeeping question

General information about how the rules are structured, not advice on your situation. Whether a particular movement is a continuous freight movement, and whether a specific carrier holds evidence satisfactory to the Minister, are questions of fact that a checklist cannot settle.

Amending prior returns 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

  1. CRA, GST/HST information for freight carriers — zero-rating of international freight, the $5 threshold, and destination-based rate determination.
  2. CRA GST/HST Memorandum 28-2, Freight Transportation Services — continuous freight movement and the documentary evidence obligation. Revised 21 September 2017, replacing the January 1999 version.
  3. Excise Tax Act — s.169 input tax credits; s.212 and s.215 tax on importation and its value; s.220.07 the provincial part; s.213 and Schedule VII non-taxable importations; Schedule VI Part VII ss.1, 6, 7, 9 and 10 for freight. Current to 21 June 2026.
  4. New Harmonized Value-added Tax System Regulations, SOR/2010-117 — s.13, place of supply for services. Current to 21 June 2026.
  5. Customs Tariff, s.20(1) — the authority under which duty is imposed, separate from the GST/HST regime. Current to 21 June 2026.
  6. CBSA, CARM financial security transition — the 20 May 2025 close of the transition period.
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