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Indirect tax sharing agreement – reasonable allocation of indirect tax law liability

Policy guidelines on the reasonable allocation of indirect tax law liability under an indirect tax sharing agreement.

Last updated 24 May 2017

A GST group may have an indirect tax sharing agreement (ITXSA) specifying the amounts each member contributes to the group's indirect tax law liabilities for a particular tax period. The ITXSA may specify:

  • fixed contribution amounts for each contributing member
  • a method of allocation under which contribution amounts are determined.

Either way, the contribution amounts calculated under the ITXSA must represent a 'reasonable allocation' of liabilities among the group's representative member and contributing members.

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QC26371