The Government is committed to cracking down on tax evasion and aggressive tax avoidance to ensure a system that is responsive and fair for all Canadians. A revised Voluntary Disclosures Program (VDP) came into effect form March 1, 2018, to narrow the eligibility criteria to access the VDP Program and to impose extra conditions on applicants, making it more difficult for those who intentionally avoid their tax obligations to benefit from the program.

To become qualify for relief, the application must be voluntary, be complete, involve the application or potential application of a penalty and, for GST/HST applications, the application or potential application of a penalty or interest, include information that is at least one year past due for income tax applications and, for GST/HST applications, at least one reporting period past due; and include payment of the estimated tax owing.

The CRA decides whether an application falls within the general or limited program on a case-by-case basis. Under the Limited Program, taxpayers will not be referred for criminal prosecution with respect to the disclosure and will not be charged gross negligence penalties. However, they will be charged other penalties and interest as applicable. In other cases, the General Program would generally apply. Under the General Program, taxpayers will not be charged penalties and will not be referred for criminal prosecution related to the information being disclosed. The CRA will provide partial interest relief for years preceding the three most recent years of returns required to be filed.

For GST/HST, excise tax, excise duty, softwood lumber products export charge and air travellers’ security charge disclosures, there are now three categories: wash transactions, the limited program and the general program.