The shield that covered departing Canadians for thirty years came down on 1 July 2021, and in Quebec, two and a half years earlier. What decides is not your passport. It is your client’s registration number.
It is nine at night in Bangkok, and you are building an invoice. You left Canada two years ago. Sold the condo, took the family, filed the departure return. You earn your living the way a whole generation now earns it: brand strategy, sponsored content, a campaign deck built on a rooftop in Thonglor, a following that a mid-size Canadian company would rather rent than build. Self-employed, no staff, no office. Tonight the invoice goes to Ryan Whitfield, who runs marketing for a firm on King Street West. $12,000 for a quarterly content plan.
Do you add 13 percent?
For thirty years the answer was no, and it was the right answer. It stopped being the right answer on 1 July 2021. Most nomads have never heard the news.
Residence first. Everything else follows.
Before the rate, before the invoice, one question: have you ceased to be a resident of Canada? Residence for GST/HST purposes is assessed on its own footing, separately from income tax, even though the connecting factors look like cousins. GST/HST Memorandum 3.4, published in April 2000 and still on the books, sets out an administrative marker. An absence of less than two years presumes you kept your residence, unless you clearly establish that every residential tie was severed on leaving. An absence of two years or longer presumes you became a non-resident, and that second branch carries a condition: you must also satisfy the other requirements for non-resident status. A home kept, a spouse left behind, dependent children, provincial health coverage: every tie counts, and one heavy tie outweighs ten light ones.
Read the income tax folio, and you would conclude differently. S5-F1-C1 carries no duration marker at all, and the CRA itself has called the old two-year rule contrary to law on the income tax side. Two regimes, two documents, one fact pattern. Welcome to the seam where nomads get caught. One more trap in the same memorandum: the 183-day deemed-resident rule under the Income Tax Act does not carry over to GST/HST. You can be a deemed resident for income tax and a non-resident for the tax on your invoices, in the same calendar year.
Small supplier, big misunderstanding
If you are still a resident, nothing changes. You bill Ryan as though you had never boarded the plane, at the rate of his province, and your input tax credits stay fully recoverable. That is where the small supplier threshold lives, and it is almost always misread. The $30,000 of section 148 is not Canadian revenue. It is worldwide taxable supplies over four consecutive calendar quarters, yours plus those of anyone associated with you. Your Singapore client counts. Your German client counts. The company your spouse controls counts. And a single quarter above the line is enough to strip the status on the spot. Nomad revenue is lumpy by nature: three quiet months, then a launch that pays for the year. Most of them cross the line in one quarter without ever noticing the year they crossed it.
Permanent establishment is not the test.
Say you are clearly a non-resident. Section 143 deems your supplies made outside Canada, and paragraph 240(1)(c) relieves you of regular registration provided you carry on no business in Canada. Note the words. Carrying on business in Canada. Not permanent establishment. Advisors constantly mix the two, and the confusion is expensive because the tests sit at very different heights. Permanent establishment is a defined term that applies to real work done elsewhere: subsection 132(2) deems you resident for the activities carried on through it, and subsection 240(6) is where security is demanded. Carrying on business is a multi-factor common-law test with a far lower ceiling, and it reopens the moment regular business trips, a borrowed desk in Toronto, or an agent acting for you enter the picture. You can have no permanent establishment in Canada and still be carrying on business there. Those two sentences are not the same sentence.
The two dates that changed everything
For thirty years, the story ended at section 143. It no longer does. Subdivision E of Division II of Part IX, sections 211.1 to 211.25, built a simplified registration regime for non-resident suppliers. Read the mechanics in the right order, because the order is the argument. Subsection 211.12(2) requires you to register as soon as your threshold amount exceeds $30,000 in any 12 months, regardless of where the supply is made. That is the provision that pierces the shield. Only once you are registered does subsection 211.14(1) deem the supply made in Canada, despite section 143. And do not be fooled by the label on the door.
The Subdivision heading says electronic commerce, but the operative definition imposes no digital condition: subsection 211.1(1) defines a specified supply as a taxable supply of intangible personal property or a service. Your strategy deck, your consulting hours, your licensed photography, all of it falls in, subject to the statutory exclusions.
Then subsection 211.14(3) sets the rate at the province where the recipient usually resides. For Ryan, that is the full 13 percent, not 5. And usual residence is not the address on your invoice: section 211.11 decides it by an indicator test. Quebec did not wait for Ottawa. Its designated regime, Chapter VIII.1 QSTA, has applied to foreign suppliers since 1 January 2019, with its own counter and its own 9.975 percent. Ottawa arrived two and a half years late to its own party.
Ryan’s number, or the counter
Here is the pivot, and it fits on a sticky note. A specified Canadian recipient is someone who has not given you acceptable evidence of registration and whose usual residence is in Canada. Both conditions, together.
The day Ryan sends you his GST/HST number, that invoice stops feeding the federal counter, and you charge nothing on it. He has nothing to self-assess, provided he uses your work exclusively in his commercial activities. Short of exclusive use, self-assessment comes back.
Two counters, two proofs. A GST/HST number closes the federal one. It takes a QST number to close the Quebec one. A business registered federally but not in Quebec shuts off one meter and leaves the other running quietly.
You collect, you remit, you recover nothing.
The regime imposes an obligation and gives you no credit. Subsection 211.17(1) says it flatly: no input tax credit, no rebate, no refund, subject to narrow exceptions. The Quebec-specified net tax under section 477.11 also carries no input tax refund.
So the freelancer in Thonglor becomes an unpaid collection agent for two treasuries, funds the compliance out of pocket, and books not a dollar of recovery. Voluntary registration under paragraph 240(3)(b) stays open, on its own conditions, and for some files it is the better trade.
Ryan will never ask you about any of this. His accountant will not either, because you are not their file.
The invoice is open on your screen: twelve thousand dollars, one line, no tax.
That line is a position. Take it knowing what it is.