How to Comply with Quebec’s New QST Rules for Non-Resident Suppliers — Montreal CPA Firm Near You

Introduction
Quebec’s sales tax system underwent a major transformation in 2019 with the introduction of the new QST (Quebec Sales Tax) rules for non-resident suppliers. These reforms were designed to ensure tax fairness in the digital economy and to level the playing field between Quebec-based and out-of-province or foreign sellers.

If you operate a business outside Quebec but sell goods or services to Quebec consumers including digital products, online platforms, or physical goods shipped into Quebec you may be legally required to register, collect, and remit QST.

At Mackisen CPA Montreal, we help Canadian and international businesses understand and comply with Quebec’s new QST rules under the Simplified Registration System. This guide explains who is affected, how to register, how to collect tax correctly, and how to stay fully compliant with Revenu Québec’s updated enforcement framework.

Legal and Regulatory Framework
The current QST system for non-residents is established under:

• Taxation Act (Quebec) s.407.1 — mandates registration for non-resident suppliers selling taxable supplies to Quebec consumers.

• Tax Administration Act (Quebec) s.93 — authorizes Revenu Québec to assess, collect, and enforce QST from non-compliant suppliers.

• Revenu Québec Bulletin TVQ.206.1 (2019) — details registration requirements for non-residents.

• Excise Tax Act (Canada) s.240(1) — provides parallel rules for GST/HST registration on cross-border sales.

These reforms apply to two categories of suppliers:

1. Canadian non-residents outside Quebec.

2. Foreign (international) suppliers selling digital or physical products to Quebec consumers.

1. Determine If You Must Register Under the New QST Rules

You are required to register under the Simplified QST Registration System if you meet all of the following:

• You do not have a physical presence or establishment in Quebec.

• You make taxable supplies of goods, services, or digital products to Quebec consumers.

• Your total sales to Quebec consumers exceed $30,000 in the past 12 months.

• Your customers are individuals or unregistered businesses (not QST registrants).

Examples of affected businesses:

• A U.S. streaming platform selling subscriptions to Quebec users.

• A European SaaS company offering cloud services to Quebec clients.

• An Ontario e-commerce store shipping directly to Quebec consumers.

Exemptions:

• Sales exclusively to QST-registered businesses in Quebec.

• Sales of exempt goods or services (e.g., financial services, certain health and education products).

2. Understand the Two Registration Systems

A. Simplified QST Registration (for Non-Residents)

• Designed for foreign and Canadian non-residents without a permanent establishment in Quebec.

• Register directly online via Revenu Québec’s Simplified System.

• You collect only QST (9.975%), not GST.

• You cannot claim Input Tax Refunds (ITRs).

• File quarterly QST returns electronically.

B. Regular QST Registration (for Businesses With Presence in Quebec)

• For companies with offices, warehouses, or employees in Quebec.

• Collect both GST and QST.

• Eligible to claim ITRs on QST paid on purchases.

• File monthly, quarterly, or annually via Mon Dossier pour les entreprises.

Mackisen Tip:
If your company plans to open an office, hire Quebec employees, or store inventory in the province, register under the regular system instead of the simplified one.

3. How to Register Under the Simplified QST System

Step 1 – Access the Registration Portal

• Visit Revenu Québec’s Simplified Registration page:
  https://www.revenuquebec.ca/en/businesses/consumption-taxes/

• Choose “Register under the specified QST system.”

Step 2 – Provide Business Details
Enter:

• Legal business name and trade name.

• Country of registration and address.

• Contact person and email address.

• Type of goods/services sold to Quebec clients.

• Estimated annual Quebec sales.

Step 3 – Submit Application and Receive QST Number

• Once approved, you’ll receive a TQ registration number (e.g., TQ1234567890).

• Keep this number on all invoices and returns.

4. Collect and Charge QST Correctly

Under the new rules, non-resident suppliers must:

• Charge 9.975% QST on taxable sales to Quebec consumers (not registered businesses).

• Display the tax separately on invoices or order confirmations.

• Include the QST registration number (TQ...) on every invoice.

Example Invoice:

Note:
Foreign suppliers do not charge GST under the simplified system.

5. File and Remit QST Returns Quarterly

• File returns online through the Simplified System portal.

• Report:

  • Total Quebec sales.

  • Total QST collected.

  • Adjustments (refunds, cancellations).

• Pay electronically in Canadian dollars via wire transfer, credit card, or online banking.

Filing deadlines:

Penalties for late filing:

• 5% of unpaid tax + 1% per month (max 12 months) under Tax Administration Act s.59(3).

6. Maintain Audit-Ready Documentation

Revenu Québec expects non-residents to maintain documentation proving compliance for at least six years under Tax Administration Act s.34:

• Sales invoices and QST charged.

• Proof of payment and remittance.

• Customer addresses confirming Quebec residency.

• Refund or credit note records.

• Correspondence with Revenu Québec.

At Mackisen CPA Montreal, we create a Non-Resident Compliance Binder that organizes all QST filings and documentation for audit defense.

7. Stay Informed About Enforcement and Policy Updates

Since 2019, Revenu Québec has expanded its enforcement program by:

• Auditing foreign digital suppliers through international tax cooperation agreements.

• Requiring payment processors and platforms (e.g., Shopify, PayPal) to verify QST registration.

• Issuing administrative penalties for repeated non-compliance.

To stay compliant:

• Subscribe to Revenu Québec’s “Consumption Taxes – Business Updates.”

• Review new bulletins (TVQ and TAA series).

• Schedule annual compliance reviews with your CPA firm.

Jurisprudence and Legal Insights
Quebec courts and tax tribunals continue to affirm the province’s jurisdiction over cross-border digital commerce:

• Airbnb Ireland UC v. Revenu Québec (2019) — established digital platforms’ obligation to register under QST.

• Netflix Inc. Ruling (2018) — confirmed foreign digital suppliers must collect QST under the new regime.

• Canderel Ltd. v. Canada (SCC 1998) — reasserted that tax filings must reflect commercial reality regardless of physical location.

These precedents confirm that Quebec’s QST system applies to economic presence, not just physical presence.

8. Penalties and Non-Compliance Risks

If you fail to register or remit QST:

• Revenu Québec may assess uncollected QST retroactively for up to four years.

• Penalties: 5% of unpaid QST + 1% per month (max 12 months).

• Interest: compounded daily under Tax Administration Act s.59(3).

• Non-payment may lead to enforcement via Canadian federal cooperation agreements.

Winning With Revenu Québec
At Mackisen CPA Montreal, we make QST compliance for non-residents seamless and risk-free:

1. Registration Support – We handle your Simplified or Regular QST registration.

2. System Integration – We configure your e-commerce or invoicing software to charge QST properly.

3. Quarterly Filing & Payment – We manage all deadlines and submissions.

4. Audit Protection – Our CPA auditors and tax lawyers handle all Revenu Québec communications.

5. Policy Monitoring – We track updates and alert you before rule changes impact your business.

Mackisen Service Hub: QST Compliance for Non-Resident Suppliers
Our Mackisen Service Hub provides end-to-end management for cross-border QST compliance:

• Simplified registration setup.

• Quarterly reporting and payment automation.

• Integration with platforms like Shopify, Amazon, or Stripe.

• Audit documentation and legal representation.

Our bilingual team of CPA auditors, tax lawyers, and compliance experts graduates of McGill, Université de Montréal, and Concordia University makes Quebec compliance effortless for non-resident businesses.

Real Client Example
A California-based SaaS company began selling subscriptions to Quebec clients but didn’t collect QST. Revenu Québec identified the company under its 2022 digital audit program and assessed $94,000 in unpaid taxes. Mackisen CPA registered them retroactively under the Simplified System, filed amended returns, and negotiated penalty relief under s.94.1 of the Tax Administration Act, reducing the liability by 80%.

Why Mackisen
With over 35 years of combined CPA and legal experience, Mackisen CPA Montreal ensures that non-resident suppliers meet every QST requirement with confidence. We simplify compliance, reduce audit risk, and protect your reputation in Quebec’s growing digital and cross-border market.

When you work with Mackisen, QST compliance isn’t a challenge it’s your competitive advantage.