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Most Canadian businesses assume that once an employee or professional advisor has been authorized to deal with the Canada Revenue Agency (“CRA”), that individual has the immediate ability to access and update all of the business’s online CRA information. As the CRA recently confirmed at an industry roundtable, that assumption is incorrect, with different authorization levels permitting different activities and access to one CRA Account not necessarily providing access to others.
We review these technical distinctions and practical considerations arising from them in the following Indirect Tax Report.
My Business Account – Authorization Levels
The CRA has recently confirmed that different “authorization levels” and different “authorization scopes” govern who may update things like business addresses, telephone numbers, email addresses and direct deposit information through the Business’s My Business Account (also known as a “MyBA”).
In many cases, representatives require Level 2 or higher access to part of the MyBA before certain functions become available, while other functions require Level 2 or higher authorization over the entire Business Number (“BN9”) rather than only a particular program account (such as a “BN11” or “BN15” account).
Some information – such as direct deposit details – is only available to legal representatives, while other representatives with lower authorization levels may be unable even to view that information.
The CRA also acknowledged that businesses frequently experience confusion because different online services perform different functions. For example, managing notification preferences is distinct from managing electronic mail delivery, and the ability to update information may depend upon which portion of MyBA the user is accessing. These distinctions are not always intuitive and can lead businesses to incorrectly conclude that the CRA’s online services are malfunctioning when, in fact, the limitation actually arises from the representative’s authorization level.
Practical Considerations
Practically, businesses should not assume that every authorized employee, accountant or lawyer has the authority necessary to manage all aspects of the business’s CRA accounts. Before significant filings, anticipated refunds or ongoing audits, businesses should review their online authorizations to confirm that the appropriate individuals have the required level of access and that all account information is current.
Only owners and directors of the Business recognized by the CRA, or individuals who have been granted Level 3 delegated authority, can generally authorize new individuals to access the MyBA. Where those individuals have retired, left the business, or are otherwise unavailable, further steps are needed to access the account.
Takeaways
The CRA’s recent comments at an industry roundtable demonstrate that My Business Account is considerably more nuanced than many businesses appreciate. Not every representative will have authority to access or modify every aspect of a taxpayer’s account. Experienced Tax Advisors can assist in getting everything straightened out with CRA, and businesses should get that done well in advance of audits, refund requests and filing deadlines.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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