Sales, Commodity and Indirect Tax


Miller Thomson’s Sales, Commodity and Indirect Tax Group provides legal advice and representation in respect of various types of tax legislation which are levied in connection with sales transactions or other activities.  We are familiar with a wide variety of tax regimes across Canada, including the following: the federal goods and services tax (GST); harmonized sales tax (HST); provincial sales tax (PST); excise tax; the Canada pension plan, employment insurance; fuel tax; carbon tax; property transfer tax, property assessment tax, foreign property purchasers, and vacancy (empty homes) tax.

We serve a range of clients, including privately-owned corporations, public companies, and multinationals. We have experience with most sectors, including charities, construction, direct sales, oil and gas, mining, real estate, manufacturing, the municipalities, universities, school boards and hospitals (MUSH) sector, non-profit organizations.

Many of our clients seek tax planning and legal advice. We take a practical results-oriented approach when providing advice. We help our clients understand the scope of their tax obligations and liabilities, develop tax-efficient plans in order to minimize duties and taxes, and help structure the client’s affairs to avoid compliance issues. We also provide timely and relevant information to clients so that they can maximize profits, minimize risk, take advantage of new opportunities and deal with challenges.

Other clients come to us in order to resolve tax controversy matters. We assist clients with  voluntary disclosures, audits, investigations, requirements to produce documents, requirements to pay, objections, appeals, assessments and collections matters. Our group has substantial tax controversy and litigation experience ranging from tax audit and appeals officers to all court levels, including the Tax Court of Canada, the Federal Court of Appeal and the Supreme Court of Canada.  Members of our group have been recognized as leading practitioners in directories such as  LEXPERT, Who’s Who Legal, and Martindale Hubbell.  They are active participants in organizations such as the Canadian Tax Foundation and the Canadian Bar Association, Commodity Tax, Customs and Trade Section.

Chambers Global Practice Guides Transfer Pricing 2023 – Canada: Law & Practice and Trends & Developments

Read about recent developments in Canadian transfer pricing including the rules governing transfer pricing, transfer pricing methods and the rise in Court intervention in transfer pricing disputes.

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Successful Tax Court of Canada Appeal

Ron Choudhury and David Chodikoff represented CanLII in a successful sales tax appeal, where the Tax Court of Canada found in favour of CanLII, on the basis that CanLII made a taxable supply with respect to the provision of a virtual library and are consequently entitled to claim input tax credits.


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