CRA Collections Limitation Period: How Long Does CRA Have to Collect Tax Debts?
Businesses often ask the following question: how long does Canada Revenue Agency (CRA) have to collect unpaid taxes. The answer lies in the CRA collections limitation period, a legally defined timeframe during which the Canada Revenue Agency can enforce tax debt collection. Generally, the CRA’s window to collect is either 6 or 10 years, depending on the type of tax debt. After this period, the debt becomes statute-barred – meaning CRA is typically prohibited from further enforcement.
Collection Periods by Tax Debt Type
- Corporate Income Tax: 10-year collection limitation period (for corporate income tax debts), starting 90 days after the CRA issues a Notice of Assessment or reassessment.
- GST/HST Remittances: 10-year limitation period for GST/HST debts, beginning the day after the Notice of Assessment is sent.
- Payroll Source Deductions: 6-year limitation period for unremitted payroll withholdings, starting the day after the CRA issues a Notice of Assessment.
When the Clock Starts and Resets
The 6- or 10-year countdown can be restarted or extended by certain actions. Any payment, written acknowledgment of the debt, or new action by CRA (for example, issuing a garnishment or registering the debt as a judgment in Federal Court) will restart the clock. Likewise, if CRA issues a reassessment – say, after an audit or discovering unreported income – a fresh limitation period begins from that new assessment date. Some events also pause the countdown: for example, if a taxpayer files a Notice of Objection, declares bankruptcy, or leaves Canada, the clock is suspended until that event concludes.
After the Limitation Period Ends
Once the CRA tax debt collection rules have run their course with no interruptions, the CRA is generally barred from taking further collection action on that debt. However, the debt itself still exists, and voluntary payments can be made even after the deadline passes (such payments are generally not expected to restart the expired limitation period).