At a glance
Distributed investment plans (DIPs) that qualify as selected listed financial institutions (SLFIs) must collect specific investor information by year-end to properly calculate their GST/HST and QST obligations. Failure to meet key deadlines could result in financial consequences. The article outlines who must provide what data, when, and how to stay compliant.
| Investor type | Information Required (as of Sept. 30, 2025) |
|---|---|
| Institutional investors A person other than an individual, DIP, or specified investor that holds units in the plan with a value of more than $10 million. | Investor percentage(s) for each HST participating province and Quebec, and number of units held (per plan/series). |
| Distributed investment plans (as investors) | Investor percentage(s) for each HST participating province and Quebec, and number of units held (per plan/series). |
| Specified investors A person is a specified investor in a DIP if they are neither an individual nor a DIP, hold units in the plan with a value of less than $10 million, have not informed the plan that they are a qualifying investor and the plan neither knows nor reasonably should know that the person is a qualifying investor. | Investor percentage(s) for each HST participating province and Quebec, and number of units held (per plan/series). |
| Selected investors A person that is neither an individual nor a DIP and that holds units of the plan having a total value of less than $10 million. | Business address that determines province of residence, and number of units held (per series). |
| Qualifying investors A person that is an SLFI or that is part of an affiliated group of investors that together holds units of the plan having a total value of $10 million or more in the investment plan. | Investor percentage(s) and number of units held (per series), plus confirmation of qualifying-investor status. |
| Securities dealers | Number of units held by clients resident in each participating province, and total units held by clients resident in Canada (per series). |
| Individuals and specified investors not residing in Canada | Not required to request information. |
Deadlines
- Oct. 15, 2025 – Deadline for DIPs to send information requests to investors
- Dec. 31, 2025 – Deadline to obtain the required information
- Investors must respond within 45 days of receiving the request
If the required information is not received by Dec. 31, 2025, the plan may be required to treat the investor as resident in the highest HST rate province (15%).
How BDO can help
Our Indirect Tax team can assist with:
- Preparing and sending investor information requests
- Reviewing responses for completeness and accuracy
- Assistance with provincial attribution percentage calculations and filings of SLFI
Brian Morcombe, Partner, Indirect Tax Practice Leader
Rouzbeh Ebrahimpour, Senior Manager, Indirect Tax Services
The information in this publication is current as of Oct. 1, 2025.
This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO Canada LLP to discuss these matters in the context of your particular circumstances. BDO Canada LLP, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it.