Critical reminder: if you received a retroactive Digital Services Tax (DST) assessment notice from the CRA last week, your 90-day clock is already ticking. Despite industry talk of repeal, the CRA is actively enforcing the 3% levy for 2022 through 2025.
You need to verify whether your group exceeds the €750 million global revenue and CAD 20 million Canadian revenue thresholds, then decide your next step quickly. That could mean payment, a structured response plan, or a formal appeal. Staying silent is not an option in the current climate.
Combined with the stricter transfer pricing rules now in force and the 31 December 2026 clean technology filing deadline, this is a moment for immediate action.
Here is what matters right now.
1. The 90-Day Clock Starts From the Notice
If you received a CRA DST assessment notice last week, your response window is already running. You generally have 90 days to act, and that time can move fast once you start gathering the figures, records, and internal approvals.
Do not treat this as something you can revisit later. The deadline matters from day one.
2. Verify Whether You Actually Meet the Thresholds
Before you decide what to do, confirm whether your group falls within scope of the 3% DST. The key thresholds are:
- €750 million in global revenue
- CAD 20 million in Canadian revenue
If your business exceeds both, your exposure needs urgent review. If the thresholds are not met, that also needs to be documented properly.
3. Staying Silent Is Not a Strategy
This is the key point. If the CRA has issued a notice, you need a response path. Doing nothing is not a safe option in the current climate.
Your next step could be:
- payment
- a structured plan
- a formal appeal
But it needs to be a deliberate decision supported by records, not silence or delay.
4. Review the Assessment Against Your Records
Pull together your digital revenue records for 2022 to 2025 and compare them against the notice. That includes platform reports, revenue allocation data, customer location support, and any internal calculation files.
You need to know whether the CRA’s position matches your own data before deciding how to proceed.
5. Decide Early How You Want to Respond
Do not wait until the final week of the 90-day window to choose between payment, a managed response plan, or a formal appeal. Each route needs preparation time.
An early decision gives you more control. A late decision usually means more risk.
6. Keep Transfer Pricing in the Same Review
The DST notice may be the immediate pressure point, but it should not be looked at in isolation. Canada’s stricter transfer pricing rules are now in force, and they create a second area of risk for groups with Canadian entities.
That means this is the right time to review intercompany transactions and make sure your files support the real economic substance of the arrangements.
7. Keep the 31 December 2026 Filing Deadline in View
The DST issue is urgent, but there is still a separate compliance opportunity on the table. Businesses looking at expanded clean technology incentives should keep the 31 December 2026 deadline visible in their planning.
This matters if your Canadian operations involve eligible spending and you do not want current enforcement activity to push incentive work off track.
8. Build a Structured Response File Now
A strong response file should include your threshold review, historic revenue support, internal calculations, notice correspondence, and your chosen response path.
This is not just about meeting a deadline. It is about protecting your position with organised records.
9. Keep Records Clean Across Every Workstream
Whether the issue is DST, transfer pricing, or clean technology claims, the practical requirement is the same: accurate and accessible data.
Clean bookkeeping, clear reconciliations, and current support files make every compliance step easier. Weak records make everything slower and riskier.
10. Act Now, Not Later
The practical message is direct. Verify the thresholds, review the notice, decide your response route, and move within the 90-day window. Payment, a structured plan, or a formal appeal may each be valid in the right case, but inaction is not.
At Sterlinx Global, we help businesses keep bookkeeping, tax calculations, filing support, and year-end compliance work organised so deadlines do not turn into avoidable problems.
Summary Checklist for April 2026
- Start the clock immediately: A CRA notice means your 90-day response window is already running.
- Verify the thresholds: Confirm whether your group exceeds €750 million global revenue and CAD 20 million Canadian revenue.
- Choose a response path: Decide between payment, a structured plan, or a formal appeal.
- Pull the records together: Review digital revenue support for 2022 to 2025.
- Do not lose sight of wider compliance: Keep transfer pricing and the 31 December 2026 clean technology deadline in view.
Frequently Asked Questions
How urgent is a CRA DST notice?
It is urgent immediately. This update stresses that the 90-day response window starts once the notice is issued.
What thresholds should businesses verify first?
You should check whether your group exceeds €750 million in global revenue and CAD 20 million in Canadian revenue.
What can businesses do after receiving a DST notice?
The update highlights three practical routes: payment, a structured plan, or a formal appeal.
Is staying silent an option if the notice looks wrong?
No. This update is clear that staying silent is not an option in the current climate. A response decision still needs to be made and documented.
What else should be reviewed at the same time?
You should also review the stricter transfer pricing rules now in force and keep the 31 December 2026 clean technology filing deadline on your radar.
Canada’s compliance environment remains active and time-sensitive. We help you keep the records, calculations, and filing work organised so you can respond with control.
Need help reviewing a CRA DST notice and building your response file?
Book a call and we will help you get the process moving quickly.
