Compliance
GST/HST Return Adjustments: Understanding CRA’s New Policy P-149 for Registrants
Discover Canada Revenue Agency’s updated guidance for adjusting GST/HST returns—what’s changed, who’s affected, and how to submit amendment requests smoothly.
By NomadicTax Research Team • 5-8 min read • July 28, 2026
## What Is Policy P-149 and What Changed
In **June 2026**, the Canada Revenue Agency published **Policy Statement P-149** titled *“Administrative Policy Regarding Adjustment to the Goods and Services Tax/Harmonized Sales Tax Return”*. This updated version replaces the older policy from September 1999 and clarifies how registrants can amend previously filed GST/HST returns. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/p-149r/administrative-policy-regarding-adjustment-goods-services-tax-harmonized-sales-tax-return.html?utm_source=openai))
Key updates include:
- Rules for **specified persons**, who now have stricter time limits for claiming input tax credits (ITCs).
- Clearer guidelines on **format** and **timing** for requests to amend returns.
- A firm statement that requests may be denied if they only increase deductions or ITCs without a corresponding increase of tax liability in that same period. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/p-149r/administrative-policy-regarding-adjustment-goods-services-tax-harmonized-sales-tax-return.html?utm_source=openai))
## Who Is a “Specified Person”?
A *specified person* usually refers to entities subject to stricter rules under tax legislation—this might include corporate groups, financial institutions, or other defined classes. Under the updated policy, such persons must claim input tax credits by the due date of the return for the last reporting period that ends within **two years** after the end of the fiscal year in which the tax becomes payable. Non-specified persons generally have up to **four years**. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/p-149r/administrative-policy-regarding-adjustment-goods-services-tax-harmonized-sales-tax-return.html?utm_source=openai))
## Timeline for Amendments: What You Should Know
| Scenario | Normal Registrants | Specified Persons |
|---|---|---|
| Claiming ITC omission | Within 4 years of filing period | Within 2 years for fiscal years ending in the relevant period |
| Requests purely increasing deductions/ITCs without tax liability increase | Generally denied if no extenuating circumstances | Stricter enforcement of denial, limited flexibility |
“Extenuating circumstances” may include **financial hardship** or situations where the deduction/ITC can only apply in that reporting period. Each case is assessed individually. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/p-149r/administrative-policy-regarding-adjustment-goods-services-tax-harmonized-sales-tax-return.html?utm_source=openai))
## Actionable Steps for Registrants
- Review previous GST/HST returns and identify potential omitted ITCs, careful about deadlines.
- If you're a specified person, mark tighter time windows. Document your fiscal year ends clearly.
- When preparing a request to amend, ensure:
* You follow the **format and submission guidelines** in P-149.
* All documentation and records are ready in case of CRA review.
## Example Scenario
**Trusted Tech Inc.**, a corporation (specified person), misses out on claiming \$20,000 of ITCs in a return covering fiscal year ending June 30, 2024. Under new policy, they must file the claim by the due date for the return covering any reporting period ending within **two years** after June 30, 2024 (i.e. by end of fiscal period ending by June 30, 2026). Waiting until much later would risk rejection without extenuating circumstances.
## Why It Matters for Compliance
This policy is crucial to prevent **unfair claims** and ensure that input tax credits don’t become tools for aggressive deductions without proper liabilities. It also encourages careful accounting and timely returns. By following the updated rules, registrants can avoid denials, audits, or penalty risk.
**Conclusion**: Updated Policy P-149 demands diligence. Know whether you’re a “specified person,” track key deadlines, and ensure claims reflect genuine liability relationships. With proper documentation and adherence, adjustments can work in your favor—and keep your filings compliant.