The Canada Revenue Agency has issued this notice to address concerns raised by the financial industry concerning the administration required where form RC4062, Request for a Group GST/HST Registration Number for Selected Listed Financial Institutions (SLFIs) with Consolidated Filing is filed to register two or more investment plans that are SLFIs, with a new single group GST/HST registration number. Where this election is made using form RC4604, each investment plan in the group and the investment plan manager must also make both a reporting entity election and a consolidated filing election using form RC4602.
The concerns raised result from the requirement to complete form RC4604 for each investment plan in situations where all the information, including signatures, will be exactly the same, with the exception of the name of the investment plan and the corresponding Business Number, where one exists. In many cases, the number of investment plans within a consolidated group of SLFI investment plans exceeds 100.
The CRA will now permit a schedule to be attached to form RC4604 that lists the other investment plans in the consolidated group, when one of the following specific conditions is met:
- all investment plans in the consolidated SLFI group make all three elections;
- all investment plans in the consolidated SLFI group make the reporting entity and the consolidated filing elections;
- not all investment plans in the consolidated SLFI group make the same elections; or
- all investment plans in the consolidated SLFI group make the same elections but the signatories are different.