CRA Issues GST/HST Notice on Investment Limited Partnerships

The Canada Revenue Agency has issued GST/HST Notice 308, “GST/HST and Investment Limited Partnerships,” which outlines new GST/HST rules for investment limited partnerships (ILPs). The Notice indicates that the definition of a selected listed financial institution (SLFI) has been expanded to include ILPs. In addition, where a general partner provides management or administrative services to its ILP, those services are now effectively subject to GST/HST (i.e., the services are deemed not to have been done by the general partner as a member of the ILP and to have been supplied otherwise than in the course of the ILP’s activities). This rule is generally effective for services rendered to an ILP by a general partner on or after September 8, 2017. Relief is available for certain ILPs with non-resident investors, subject to specific conditions. 

The publication also explains the transitional rules for services provided under agreements entered into prior to September 8 and provides examples regarding the application of GST/HST to services provided by the general partner of an ILP in various situations. Previously, management services provided to an ILP by its general partner were not necessarily subject to GST/HST.