If you know you should have been registered, or you know you collected GST and didn't remit it, and CRA hasn't sent you anything yet — you're in a different position than the one described in Parts 1 and 2. Everything in those articles still applies to the underlying tax you owe. But because CRA hasn't found the problem yet, you still have the option to come forward first. That matters, because coming forward voluntarily and getting caught are treated very differently.
Coming Forward First: The Voluntary Disclosures Program
The main route for coming forward on your own is the CRA's Voluntary Disclosures Program (VDP), set out in CRA Information Circular IC00-1R6. The basic idea is simple: if you tell the CRA about a problem before they find it themselves, you can get relief from penalties, and in some cases relief from part of the interest as well.
What VDP does not do is make the GST/HST itself go away. You still have to pay what you actually owe — VDP is about reducing the penalties and interest stacked on top of that amount, not the underlying tax.
Every Month You Wait, the Bill Gets Bigger
This is worth being direct about: registering and filing doesn't just resolve the problem, it stops it from getting worse. Interest under ETA s. 280 and the late-filing penalty under ETA s. 280.1 don't pause while you're deciding what to do — they keep building for every month registration is delayed. There's no upside to waiting longer to figure this out. The only thing that changes the longer you wait is the size of the number.
Filing Is What Starts the 4-Year Clock
As covered in Part 1, the CRA's normal four-year window to reassess you only starts once a return has actually been filed (ETA s. 298(1)). Until you file, that clock isn't running — meaning those periods stay open indefinitely. Filing the outstanding returns, even late, is what finally gets that clock started. It's one more reason why sitting on the problem doesn't help you: not filing doesn't wait out the four years, it just delays the point where the four years can even begin.
VDP Has Rules — It's Not Automatic
To actually qualify for VDP relief, your disclosure generally needs to meet a few conditions:
- It has to be voluntary — made before CRA has taken any enforcement action related to the matter.
- It has to be complete — covering the full picture, not just part of it.
- It has to involve a penalty — there has to be an actual penalty at stake for relief to apply to.
- It has to be at least one reporting period past due.
These are threshold requirements, not a guarantee. Meeting them means you're eligible to apply — it doesn't mean CRA will automatically grant relief, and it doesn't remove their discretion in how much relief to give.
The Tax-Extra vs. Tax-Included Question Doesn't Change
If part of your situation involves periods where you never charged GST at all, the tax-extra vs. tax-included analysis from Part 1 still applies exactly the same way — whether you come forward voluntarily or CRA finds the problem on its own. Coming forward through VDP affects the penalties and interest around the number. It doesn't change how the number itself gets calculated.
This Is the Point Where DIY Usually Stops Making Sense
How much VDP relief you can realistically get — and how the disclosure should even be structured — depends heavily on the specifics: how many years are involved, how much money is involved, and whether GST was actually collected from customers during any of those periods (which, as Part 2 covers, is treated more seriously than never charging it at all). This isn't a situation with one standard answer. It's genuinely fact-specific, and it's the point in this whole series where trying to handle it yourself usually stops being the right call.
Quick Reference: Coming Forward Before CRA Contacts You
| Issue | Legislative / Program Basis | What It Means for You |
|---|---|---|
| Main proactive route | CRA Information Circular IC00-1R6 | Can get relief from penalties and some interest — the tax owing still has to be paid |
| Interest keeps accruing until you register | ETA s. 280 | Compounds daily for every month you delay |
| Late-filing penalty keeps accruing | ETA s. 280.1 | 1% + 0.25% per month late, capped at 12 months |
| 4-year reassessment clock | ETA s. 298(1) | Only starts once a return is filed — filing is what starts it |
| VDP eligibility conditions | IC00-1R6 | Voluntary, complete, involves a penalty, at least one period past due |
| Tax-extra vs. tax-included | ETA ss. 165, 221, 223; CRA P-118R | Decided the same way regardless of whether disclosure is voluntary |
The Bottom Line
If CRA hasn't contacted you yet, you have an option that disappears the moment they do: coming forward first. It won't erase what you owe, but it can meaningfully reduce the penalties and interest sitting on top of it — and every month you wait is a month that number keeps growing instead of shrinking. Because how VDP relief plays out depends so much on your specific numbers and history, this is the stage in the process where it's worth talking to someone before you file anything.
This article is for general informational purposes only and does not constitute legal or tax advice. For guidance specific to your situation, consult a CPA or Canadian tax professional.