Writing a Service Revenue Recognition Policy Under ASPE
The contract triage matrix, the policy memo template and the deferred revenue schedule we build for service companies reporting under Canadian ASPE.
RegionOne return, and a rate the customer decides
Harmonisation removes the second return and moves the difficulty upstream. What has to be right here is the invoice, and it has to be right at the moment it is issued.
Nova Scotia, New Brunswick, Newfoundland and Labrador and Prince Edward Island all harmonised their provincial sales tax into the federal one, so a company selling into them files one return with the federal agency and nothing provincial at all. That is a genuine simplification and it is where most descriptions of the region stop. It should not be. The participating provinces do not all apply the provincial part at the same rate, and they are less uniform now than they used to be. So the question a finance function has to answer here is not which return to file. It is which rate this particular sale attracts, decided by rules that look at the supply rather than at the seller, and that answer has to be right on the invoice when it is issued, because the return is only a summary of whatever the billing system already did.
DetailWhat the finance function actually carries
The rules turn on the supply and there is not one of them, there are three. For goods, the province is where the goods are legally delivered to the recipient, with deeming rules that fix delivery at the destination named in the carriage contract or at the point possession passes to a carrier the supplier retained on the recipient's behalf. It is not the customer's billing address and it is not where the seller sits. A short lease follows where the property is delivered or made available, while a longer one follows the ordinary location of the property as the parties agreed it. For services the lead rule is different again: the recipient's home or business address in Canada obtained in the ordinary course of the supplier's business, falling to where the Canadian part of the work is performed only where no Canadian address is obtained. That address has to be a real physical location, so an email address or an internet address does not satisfy it. For intangible property the lead test is where the Canadian rights may be used, with the recipient's address entering only as a tiebreak. Three tests, one invoice, and a customer record that either carries the right field or does not.
That is a systems problem before it is a tax problem, which is precisely why it belongs on a finance operations site rather than a tax one. The information the rules need has to be captured when the customer is set up and when the order is taken, not reconstructed at period end out of a shipping report. A customer master holding one address for everything cannot distinguish where a service recipient is located from where goods were delivered, and a billing system with one provincial tax code per customer will charge the same rate on a shipment to a different province as it does on everything else. The failure is quiet and it is the wrong kind of quiet. Undercharging is a liability the company absorbs, because the tax was owed whether or not anybody billed it. Overcharging is a customer problem that surfaces months later when somebody in their accounts payable finally reads a line. Neither is caught by a return that adds up, because a return built out of the billing system adds up either way.
On the employer side the four provinces are not one place, and the difference matters if you are hiring across them. Newfoundland and Labrador levies a payroll tax on employers, calculated on remuneration paid to employees who report for work in the province and administered by the provincial finance department. Nova Scotia, New Brunswick and Prince Edward Island have no employer health tax or payroll levy at all, which is worth knowing precisely because the neighbouring province does. Each of the four has its own workers' compensation authority, separately named and separately administered rather than branches of one body, and registration is not automatic on hiring a person: in Nova Scotia and New Brunswick it turns on whether the industry is covered and on a minimum number of workers, below which coverage is voluntary, while the other two reach further. Corporate income tax across all four is administered federally, so there is no provincial corporate return anywhere in the region.
EngagementsWhat changes about the work
The customer master has to carry the fields the place of supply rules actually read, which is a different set for goods, for services and for rights, and the tax code list has to express more than one provincial rate rather than one per customer.
Remediation across these provinces means walking a year of invoices against where each supply actually went, because a return assembled out of a billing system reconciles perfectly whether the rates it was built from were right or wrong.
Revenue reported by province is built from the place of supply rather than from the customer's head office address, or the pack shows growth where the contracts are signed and nothing where the work is delivered.
BoundaryWhat this firm does not do here
This firm does not determine the place of supply for a particular transaction, does not decide which rate a given invoice should carry, and does not file the return. Those are positions and they belong with your external accountant, who is better asked once about the transaction types you actually have than repeatedly about individual invoices. What this firm does is make the answer applicable: the fields the rules read captured in the customer master and on the order, a tax code set that can express more than one provincial rate rather than one per customer, and a period end test of what was charged against where the supply actually went rather than against the total.
Everything here is finance operations: which registrations exist, which returns exist, where each one sits in the close, and who owns the step. Whether a particular filing position is correct is a question for the company's external accountant, and this firm routes it there rather than answering it. The two jobs are different and a company needs both.
KNA Group works from Ottawa and has no office, no staff and no phone line anywhere else. These pages are not a claim to be local to you. They describe what changes in a finance function when a company has people or an entity in a place, and the work is delivered remotely inside the ledger, bank and tools the company already uses.
FAQAsked by companies with people here
No, and a process built on the assumption that they do is now wrong. The provincial part of the harmonised tax does not apply at the same rate in every participating province, and the region is less uniform than it once was. Because it is a single return, nothing in the filing will tell you a rate was wrong. The only place it can be caught is the invoice, at the moment it is issued.
For goods it follows where they are legally delivered to the recipient, with deeming rules pointing at the destination named in the carriage contract or at the point possession passes to a carrier you retained on their behalf. So the shipping destination does the work and the head office address does not, which is the reverse of how most customer records are built. For a service the test is different again, and the recipient's Canadian address obtained in the ordinary course leads.
Yes, and the services rule is the one most often applied backwards. The lead test is the recipient's home or business address in Canada obtained in the ordinary course of your business, and only where no Canadian address is obtained does it fall to where the work was performed. That address has to be a real physical location, so an email address or an internet address does not qualify. Where your people sat while doing the work is not the first question.
There is an employer payroll tax, calculated on remuneration paid to employees who report for work in the province and administered by the provincial finance department. It is employer-paid, so nothing is withheld from anybody and nothing about it will appear in a source deduction reconciliation. The neighbouring provinces have no equivalent, which is exactly the sort of asymmetry that gets missed when a company treats the region as one place.
Where you have workers, and subject to each province's own tests, which are not the same tests. Nova Scotia and New Brunswick gate mandatory registration on the industry being covered and on a minimum number of workers, below which coverage is voluntary. The other two reach further. Each is a separate registration with separate reporting, and the four are separately named authorities rather than branches of a single body.
ReadThe working documents behind this
The contract triage matrix, the policy memo template and the deferred revenue schedule we build for service companies reporting under Canadian ASPE.
One monthly pack followed from the close lock to the reader's inbox: the order the pages go in, the page that leads, and the seven things we take out.
A cutover walkthrough for rebuilding a chart of accounts: the mapping table, opening balances, restated comparatives, and the proofs that keep history intact.
NextThe other regions
Bring a quarter of invoices into these provinces and the customer records behind them. The test is quick and it is the only one that finds anything: whether the rate on each invoice matches where that supply actually went, rather than whether the return added up.