BOS CRA Rules

Rules · TIM

TIM-05 — Pass-through costs and agency. Incurred as agent

Stale — principle only — The principle holds; a figure or date in it may not. Check the figure before you use it.

Pass-through costs and agency. Incurred as agent: the reimbursement is not consideration for a supply, is not taxable, and the agent claims no ITC. Incurred as principal and rebilled: it is part of the consideration for the agent's own supply and is fully taxable, and the agent claims the ITC. CRA closes the labelling loophole explicitly — a cost "forms part of the payment for the agent's service, even though [it] may be separately itemized and listed as a 'reimbursement' on an invoice." Three essential qualities of agency: consent of both parties, authority to affect the principal's legal position, and the principal's control. CRA also treats the bookkeeping as evidence — a true agent does not record the amount as its own expense

Sources

Record

Anchor ID
TIM-05 (permanent)
Jurisdiction
FED
Section
2.4 Timing of tax — deposits, prepayments, progress payments, holdbacks
Verified
2026-08-27 — by a person, against the source
Review cycle
legislative

Changes mentioning TIM-05

DateChange
28 Aug 2026

Added local mirror paths to every anchor whose CRA source is actually held in Sources/, so the index no longer depends on the "grep by anchor ID" step to find a document. Checked each of the 96 anchors' Source URLs against the 51 documents in the library (36 mirrors with provenance front-matter, 15 plain-converted guides with none) and against the front-matter anchors: field where one exists. Where a plain guide has no front-matter (T4012, T4002, RC188, P113, 5000-G and others), verified the match by grepping the guide's own text for the anchor's specific figures or section titles before adding the path — e.g., T4012's "List of CCA rates and classes" section for TAX-09, T4002's line 8523/9945/9281 sections for TAX-05 to TAX-07 and TAX-11, P113's "advantage"/"eligible amount"/80% definitions for NPO-06 and NPO-07. Two claims were checked and rejected rather than added: RC188 itself warns against extending its six-year/location text to REC-02 and REC-03, so those keep only the live source; P113's "Official donation receipts" section defers to the charities-giving page rather than listing receipt contents, so NPO-08 keeps only the live source; and P113 contains no $75/10% de minimis figure, flagged inline on NPO-07 rather than silently added. Deliberately left unmirrored, per the library's existing design: the 34 living CRA topic pages (REG-04 to REG-08, RATE-01, most of PAY, TAX-13, NPO-03/04, ITC-02 to ITC-04, XB-01/03), the 7 rate pages (all of Part 3), the 5 provincial pages (all of Part 2.11), and SOR/91-45 (external legislation, not part of this library) — these are living-only by design and a snapshot would misrepresent them as fixed. TIM-05 and NPO-05 each gained two mirror paths, one per source cited. No rule, figure, date or flag was changed — this pass only adds path metadata already implied by the front-matter and by Part 4's "Still valid for" columns

28 Aug 2026

Mirroring complete — all 34 non-guide sources now held in Sources/ with provenance front-matter and descriptive filenames. Confirmed against source: RC4110 cancelled 2026-01-30 (exact wording on the record page); REG-09's Quick Method exclusion list verbatim, so BOS itself cannot elect it; REC-01's six-year rule, which runs from the end of the last tax year the records relate to; T4117 unrevised since 2020-02-28 (Rev. 19); the 8-4 ban (11×$30, 8×$150, 0×$500); 17-1 reproduces neither (l) nor (n)–(t); TIM-05's agency rule and CRA's rejection of mere labelling. Corrected: the "public purpose" phrase does not appear in 18-4 and 23 June 2022 is a publication-record date, not an in-document one. Closed: the NPO-05 worksheet gap, resolved by RC4034 Rev. 25

The full changelog