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ARTICLE · 29 MAY 2026

GST 201: Bad Debt GST Recovery Has Strict Rules

When businesses face unpaid invoices, section 231 of the Excise Tax Act offers a pathway to recover GST/HST previously remitted on uncollectible debts. However, as a recent Tax Court decision demonstrates, this relief comes with strict technical requirements that must be meticulously followed. Understanding these conditions and avoiding common pitfalls is essential for businesses seeking to maximize their tax recovery on bad debts.

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For businesses dealing with unpaid invoices, section 231 of the Excise Tax Act (ETA) offers a vital form of relief: the ability to recover GST/HST previously remitted on debts that have become uncollectible. However, as the recent Tax Court of Canada (TCC) decision Heydary Green Professional Corporation v. The King, 2026 TCC 69 (“Heydary”) demonstrates, this relief is only available to those who strictly adhere to the ETA’s technical requirements.

In this GST 201 Series blog, we review section 231 and the statutory rules for bad debts, as well as what Heydary shows about the process that must be followed to benefit from this section.

The Section 231 Regime for Bad Debts

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