Insurance services by intermediaries subject to tax

Published September 22, 2023

In July 2023, the Canada Revenue Agency (CRA) released GST/HST Notice 325 (Notice) providing clarification and guidance on the application of GST/HST to supplies made, directly or indirectly, to an insurer by certain insurance intermediaries to aid insurers and intermediaries in determining whether the services they provide are subject to GST/HST or exempt.

The Notice intends to provide clarity and is a follow up to CRA’s 2019 technical interpretation on the taxable status of commissions paid to insurance intermediaries and the application of GST/HST to services supplied by insurance intermediaries.

The GST/HST Notice 325 includes examples of situations involving a range of services that may be provided by insurance intermediaries accompanied by an analysis for each of the examples. The first five examples reflect scenarios where the intermediary’s supply to the insurer is exempt, while the sixth and seventh examples reflect scenarios where the intermediary’s supply to the insurer is not exempt.
Although the CRA is accepting feedback on the Notice during a three-month comment period, as stated in the Notice, it can be expected that the CRA’s summary is an accurate interpretation of the law. Licensees who have questions pertaining to the Notice should contact CRA directly and/or seek advice from a professional specializing in such matters.
Insurance Council Code of Conduct requires licensees to be aware of and comply with all applicable and governing legislation that may impact their practice. To learn more about licensee responsibilities and requirements, please visit the Licensee Resources page of our website or contact a member of our Practice & Quality Assurance team at or 604-695-2008.