If you sell on Amazon Canada from outside Canada, the question of whether to register for GST/HST comes up early and the answer is more nuanced than “always” or “never.” Amazon collects sales tax on your Canadian orders under marketplace facilitator rules whether or not you are registered, so the short-term pressure to register feels low. The actual case for registration is on the other side of the ledger: the GST you are already paying on Amazon fees, advertising, freight, and customs, which becomes recoverable as input tax credits the moment you become a registrant.
This guide walks through the framework: when registration becomes mandatory under CRA rules, when it is optional but recommended, what input tax credits you can recover, and how to set the registration up end-to-end.
The short answer
Non-residents are not automatically required to register for Canadian GST/HST just because they sell on Amazon Canada or use FBA Canada. Registration becomes mandatory only if you are carrying on business in Canada AND your worldwide taxable sales exceed $30,000 CAD in any rolling 12-month period. The carrying-on-business question is multi-factor and turns on your overall facts, not on any single element. Even where mandatory registration is unclear, the practical recommendation for most non-resident Amazon FBA sellers is to register voluntarily so you can claim back the GST you are already paying on Amazon fees, advertising, freight, customs, and inbound shipping. The recoverable input tax credits frequently exceed the GST collected and remitted on direct sales.
The two questions that decide whether registration is mandatory
Two questions, in order:
1. Are you carrying on business in Canada?
CRA does not use a single bright-line test. It looks at the totality of your activity in Canada and weighs a list of factors:
- Where contracts of sale are made
- Where your assets are located
- Where your employees or agents are based
- Where your bank accounts are held
- Where you solicit orders from
- Where deliveries are made
- Where business decisions are made
- Where backup or assistance is provided to customers
- Where inventory is held
No single factor is decisive. Two non-resident Amazon FBA sellers with identical Canadian sales can land on opposite sides of the line depending on how the rest of the factors stack up. Inventory storage in a Canadian fulfillment centre is one of the factors CRA weighs, but it is not, by itself, a trigger.
This is the part that needs an actual assessment of your business by someone who knows the case law and the CRA practice. Self-determining based on one factor is a common path to either over-registering when not required or under-registering when required.
2. Are your worldwide taxable sales over $30,000 CAD?
If you have concluded (with proper advice) that you are carrying on business in Canada, the next test is the small supplier rule. Registration is mandatory once your worldwide taxable sales exceed $30,000 CAD in any four consecutive calendar quarters. The threshold is worldwide, not Canada-only. A UK seller with $200,000 in UK sales and $5,000 in Canadian FBA sales is well over the $30k threshold for these purposes if they are carrying on business in Canada.
You have 29 days from the day you cross the threshold to apply for registration.
Amazon collects on your behalf either way
Whether or not you are registered, Amazon Canada collects and remits the applicable sales tax on your Canadian orders. The mechanics:
- Not registered: Amazon collects GST/HST and remits it directly to CRA on your behalf as the marketplace facilitator. Amazon collects and remits provincial PST/QST in BC, SK, MB, and QC directly to those provinces.
- Registered, with your GST/HST number entered in Seller Central: Amazon collects the GST/HST and passes it to you in your disbursement to remit yourself. Amazon continues to handle the BC/SK/MB/QC provincial PST or QST directly.
Full mechanics are covered in our companion guide on how Amazon collects and remits GST/HST.
The takeaway here is that the marketplace facilitator collection protects the CRA’s revenue on the sale itself. It does not affect your separate obligation to register if you are required to, and it does not give you any ability to claim back the GST you are paying on Canadian business inputs. That recovery only opens up after you register.
The real case for registering: input tax credit recovery
This is the part most non-resident sellers overlook. Once you are GST/HST registered, you can claim back the GST/HST you have paid on Canadian business inputs. For a non-resident Amazon FBA seller, that includes:
- Amazon seller fees (referral fees, FBA fees, storage fees, removal fees)
- Amazon advertising spend (Sponsored Products, Sponsored Brands, Sponsored Display)
- Freight forwarder fees on inbound shipments
- Customs brokerage fees
- Customs duties and import GST on goods you imported
- Canadian-side software subscriptions (Helium 10 Canada, Taxomate, etc.)
- Translation and localization services
- Canadian legal and professional fees
For most non-resident Amazon FBA sellers, the recoverable input tax credits on the items above exceed the GST/HST that would have been collected and remitted on direct sales in the early years of trading. That puts you in a net refund position. Failing to register means paying GST on every one of these costs with no path to recovery.
Once you register, you can claim ITCs on Canadian business costs going back up to four years before registration, provided you have proper documentation (invoices showing the GST/HST charged, vendor registration numbers, etc.). For sellers who have been operating for a few years without a registration, the lookback recovery can be substantial.
Worked example: a UK seller’s ITC math
A London-based Amazon FBA Canada seller, 12 months of activity
A UK-based seller does $180,000 CAD of Amazon Canada sales over 12 months. Amazon’s fees (referral, FBA, storage) come to roughly 28% of revenue: $50,400 of fees, which are subject to GST/HST at an average effective rate around 13%. Advertising spend is $14,000, also GST-bearing. Freight and customs duties on inbound inventory are another $11,000, of which roughly $1,400 is recoverable GST.
GST/HST on advertising ($14,000 x ~13%) ……….. $ 1,820
GST/HST on freight + customs (recoverable) …….. $ 1,400
SUBTOTAL recoverable as ITCs …………………. $ 9,772
GST/HST collected on direct sales (passed back by Amazon to remit, avg ~11% on $180k) … $19,800
Net remittance to CRA after ITC claim …………. $10,028
Unregistered, the seller pays the $9,772 in GST embedded in fees, advertising, and freight with no recovery, and Amazon remits all the $19,800 of sales tax directly to CRA on their behalf with nothing flowing back. Registering recovers the $9,772 every year, in cash, every year you remain a registrant.
How registration works for non-residents
The mechanics are straightforward but document-heavy.
- Get a Canadian Business Number (BN). Apply via Form RC1 with CRA. Non-residents typically apply by mail or fax. Plan for two to four weeks.
- Open a GST/HST program account (RT) tied to your BN. You can request it on the same RC1 form or open it later via RC1A.
- Authorize a Canadian representative if needed. CRA generally requires or strongly prefers a Canadian-resident representative for non-resident accounts. We act in this role for our non-resident clients.
- Enter your 15-digit GST/HST number in Amazon Seller Central. Settings > Tax Settings. Amazon verifies the number with CRA before the tax-handling flip takes effect on new orders.
- File your first GST/HST return. Filing frequency (monthly, quarterly, or annual) is assigned by CRA based on annual revenue. Most new non-resident registrants start on an annual filing frequency. The first return is where you claim the lookback ITCs.
Full registration process details, including CRA telephone handling and Canadian representative requirements, are in our companion post GST/HST Registration for Non-Resident Amazon.ca Sellers.
CARM and BSF900 if you import physical inventory
Separate from GST/HST, if you ship physical inventory into Canada you are also an importer in CBSA’s eyes. Since May 2024, non-resident importers based outside Canada, the US, or Mexico must file Form BSF900 through the CARM portal to designate a Canadian record custodian. Without an approved BSF900, you cannot maintain an active import-export business account and your shipments will be held at the border. See our walkthrough on how to file the BSF900 for the customs side.
Most non-resident FBA sellers who address their GST/HST registration also address the BSF900 at the same time, since the two registrations affect the same shipments and the same overall compliance posture. We handle both in tandem through our Non-Resident GST/HST and CBSA Record Custody services, with a bundled price when both are needed.
Frequently asked questions
Do I need to register for GST/HST if I sell on Amazon FBA Canada from outside Canada?
Not automatically. Registration is mandatory only if you are carrying on business in Canada AND your worldwide taxable sales exceed $30,000 CAD in any rolling 12-month period. The carrying-on-business test is multi-factor and depends on your overall facts. Most non-resident Amazon FBA sellers register voluntarily anyway because the recoverable input tax credits on Amazon fees, advertising, freight, and customs typically exceed the cost of remitting GST on direct sales.
Does storing inventory in Amazon FBA Canada mean I am carrying on business in Canada?
No, not on its own. Inventory location is one of several factors CRA weighs (contracts, assets, employees, bank accounts, decisions, agents, where business is solicited, where deliveries are made, etc.). The conclusion depends on your overall Canadian footprint, not on any single factor. Two non-resident FBA sellers with identical sales can land on opposite sides of the line.
What is the $30,000 threshold based on?
Worldwide taxable revenue in any four consecutive calendar quarters. It is not Canada-only revenue. A non-resident with $200,000 of UK sales and $5,000 of Canadian FBA sales is over the threshold for these purposes if the carrying-on-business test is met.
What input tax credits can I claim back as a registered non-resident Amazon seller?
The GST/HST you pay on Amazon seller fees, FBA fees, storage fees, advertising spend, freight forwarding, customs brokerage, import GST on goods, Canadian software subscriptions, Canadian professional fees, and other Canadian business inputs. For most non-resident FBA sellers these ITCs exceed the GST/HST collected on direct sales, putting them in a net refund position.
How far back can I claim ITCs after I register?
Up to four years before the date of registration, provided you have proper documentation: invoices showing the GST/HST charged, the vendor’s registration number, and proof of payment. For sellers who have been trading for a few years without registering, the lookback can recover meaningful amounts of cash.
How long does GST/HST registration take for a non-resident?
Two to six weeks for the BN and the GST/HST account, depending on CRA workload and how cleanly your supporting documents match. Amazon’s verification of the number in Seller Central adds another few days.
What if I have been selling for several years and never registered?
You have two reasonable paths: file a Voluntary Disclosures Program (VDP) application with CRA, which can reduce penalties and interest if you come forward before they contact you; or simply register now and claim the four-year lookback on ITCs. Which path is right depends on whether mandatory registration would have applied to you historically. We assess this for clients before recommending one approach over the other.
Do I also need to file BSF900 for CARM?
If you import physical inventory into Canada from outside Canada, the US, or Mexico, yes. BSF900 is a CBSA customs-side filing that designates your Canadian record custodian under Memorandum D17-1-21. Without it, you cannot maintain an active import-export business account. See our companion guide on how to file the BSF900.
What to do next
If you are a non-resident Amazon FBA Canada seller and you are not registered for GST/HST, the right next step is an assessment, not a self-determination. We help non-resident sellers work through both questions (carrying on business + threshold), look at the ITC recovery opportunity in your specific cost structure, and handle the full registration and ongoing filings if it is the right call. If you also import physical inventory, we run the BSF900 / CARM side in parallel.
Get in touch with a short note about where you are based, what you sell on Amazon Canada, your rough monthly volume, and whether you also use 3PL or import physical inventory. We respond within one business day with a fixed-fee quote covering the registration assessment, the registration itself, and the ongoing GST/HST filings. Pricing on our pricing page, including the bundled rate for combined GST/HST and CBSA Record Custody clients.
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