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ARTICLE · 16 SEPTEMBER 2026

CRA To Prioritize Advance Ruling Requests For Large Investments

Osler, Hoskin & Harcourt LLP
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The Canada Revenue Agency has announced a new priority system for advance income tax ruling requests, targeting investments of at least $1 billion in Canada. This initiative aims to accelerate the tax certainty process for major investors by reducing processing times and providing binding guidance on how specific Income Tax Act provisions apply to proposed transactions.

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Timothy Hughes
Timothy Hughes
Ilana Ludwin
Ilana Ludwin
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On September 14, 2026, the Minister of Finance and National Revenue announced that the Canada Revenue Agency (CRA) will, as of now, prioritize advance income tax ruling (AITR) requests relating to investments of at least $1 billion in Canada. The news release, issued on the first day of the federal government’s Investment Summit, states that this change is intended to provide “the clarity and certainty [major investors] need to move forward with confidence to get projects built” by reducing risks and informing investors’ financing decisions.

AITRs allow taxpayers to request the CRA’s view of how specific provisions of the Income Tax Act (Canada) apply to a proposed transaction. Once issued, AITRs are binding on the CRA for the particular taxpayer (subject to stated requirements or caveats). The news release notes that AITRS provide “the highest level of tax certainty available from the CRA.”

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