RegionA second revenue authority, end to end

Quebec: two tax administrations, and a close that serves both

A company with an establishment in Quebec does not file a provincial variation of a federal return. It files with a second revenue authority, on its own forms, on its own remittance stream, all year.

Every other province except one has handed its corporate income tax to the federal agency to collect. Quebec has not, and that single fact reshapes a finance function more than anything else in this section. A company with an establishment in the province files a Quebec corporate return with Revenu Québec as well as the federal one. Its payroll runs two remittance streams to two authorities, with different employer contributions on each. Its sales tax is reported to the province on a combined return that carries the federal tax inside it, which is the reverse of what most people expect. And its year end produces a second set of wage slips, because the federal slip is specifically not to show Quebec income tax. None of that is a variation on the federal relationship. It is a parallel one, and the close has to carry both.

DetailWhat the finance function actually carries

Start with payroll, because that is where the duplication is most visible and most often half done. Where an employee's province of employment is Quebec, provincial income tax is deducted and remitted to Revenu Québec on the province's own schedule while federal income tax continues to the federal agency on the federal one. The pension plan is the Québec Pension Plan rather than the Canada Pension Plan, decided by province of employment rather than by where the employee lives. The employee's employment insurance deduction is reduced because the province runs its own parental insurance plan, and the employer contributes to a provincial health services fund with no federal counterpart. The workers' compensation premium is the trap. Classification and rate come from the CNESST and the annual wage declaration goes to the CNESST, but the money is paid to Revenu Québec through the same periodic remittance as everything else. A close that expects a premium invoice from a board, which is how it works in Ontario, will look for a document that never arrives.

Sales tax runs the other way from the intuition. Revenu Québec administers the federal tax inside the province on the federal agency's behalf, so a registrant for both taxes files one combined return with the province rather than one with each. The registrations are still separate, the account numbers are separate, and the two taxes are reported in their own boxes on that one form, so reconciling one has proved nothing about the other. Selected listed financial institutions are the exception and run entirely the other way, administered federally for both. On the corporate side the province requires its own return from any corporation that had an establishment there at any point in the year, and takes its own instalments on its own schedule. That is a second tax provision to support, a second assessment to agree, and a second set of balances that has to reconcile to the first.

Then there is the language of the documents, which is the part most often either ignored or overstated. The Charter of the French Language requires invoices, receipts and documents of the same nature to be drawn up in French, and it reaches contracts pre-determined by one party, offers of employment, written employment contracts and written communications with staff. It does not require your general ledger to be in French. There is no provision in the Charter about books of account at all, and a firm telling you to translate your chart of accounts is selling you something. What is caught is the document that leaves your building, which makes this a billing system question and a human resources document question rather than a bookkeeping one. Above a stated size an enterprise also registers with the province's language office and transmits an analysis of its linguistic situation. Separately from all of it, an enterprise carrying on activity in the province sits on the provincial enterprise register and files an updating declaration every year whether anything changed or not.

EngagementsWhat changes about the work

The same engagements, carrying something extra here.

01The Monthly Close, Run as a Service

The calendar carries two remittance deadlines rather than one, and the workers' compensation premium is picked up as a periodic payment inside the provincial remittance rather than waited on as an annual invoice from a board.

02Segregation of Duties in a 15 Person Company

Two payroll authorities means two ways for a remittance to go missing and only one of them shows on a federal account statement. The control is a reconciliation of both remittance accounts to the payroll register every period, reviewed by a second person.

03The Reporting Pack We Deliver Every Month

A pack for a company with people on both sides of the river reports the two payroll cost structures separately rather than blending them, because the employer contributions differ and a blended labour cost hides which establishment is actually the expensive one to staff.

BoundaryWhat this firm does not do here

This firm does not prepare or sign the Quebec corporate return, does not give an opinion on whether a supply is taxable for provincial purposes, and does not advise on Charter of the French Language compliance, which is a legal question and belongs with counsel. It does not translate documents and it does not act as your representative with either authority. What it does is put the second remittance stream, the second return and the second set of year end slips on the close calendar with an owner against each, and prove the balances behind them reconcile before anybody signs.

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

FAQ: Quebec

We have one person in Montreal and everyone else in Ontario. Does that pull us into all of this?

The payroll half of it, immediately. Province of employment is decided per employee, so that one person moves onto Quebec income tax withholding, the Québec Pension Plan, the reduced employment insurance deduction and the provincial health services fund, remitted to Revenu Québec on its own account. The corporate return is a separate question that turns on whether the company has an establishment in the province rather than on having a person there. Those are two different tests and they are routinely answered as though they were one.

Do our books have to be in French?

No. The Charter of the French Language contains no provision about books of account, and nothing requires a general ledger, a chart of accounts or an internal reconciliation to be in French. What the Charter reaches is the document that leaves the building: invoices, receipts and documents of the same nature, contracts pre-determined by one party, offers of employment and written communications with staff. That makes it a billing system and human resources question. Whether a specific document is caught is a legal question for counsel.

Who do we actually pay the workers' compensation premium to?

Revenu Québec, through the same periodic remittance as your source deductions, even though the CNESST is the body you register with, the body that classifies you and the body that receives the annual wage declaration. That split catches everyone who has run payroll in Ontario, where the board bills you and you pay the board. A close looking for a separate premium invoice will not find one, and the accrual drifts quietly until somebody reconciles the remittance line.

We file sales tax federally everywhere else. Is Quebec really different?

It is, and in the opposite direction from the usual guess. Revenu Québec administers the federal tax inside the province on the federal agency's behalf, so a registrant for both files a single combined return with the province covering both taxes. The registrations remain separate and each tax is reported in its own boxes, so reconciling one proves nothing about the other. Selected listed financial institutions are the exception and are administered federally for both.

Does the year end slip situation change anything for us in practice?

It changes who produces what. A Quebec employee still gets a federal wage slip, but that slip is specifically not to carry Quebec income tax, which appears instead on a provincial slip issued alongside it with its own summary filed with the province. Year end payroll becomes two filings on two systems rather than one, and a payroll provider that handles the federal side competently can still leave the provincial summary unfiled without anything bouncing.

ReadThe working documents behind this

NextThe other regions

A file that has to satisfy two authorities.

Bring the last few periods and whoever currently touches the provincial account. An hour is usually enough to establish which of the two relationships is being maintained properly and which one has been running on the assumption that the payroll provider had it.