Back Version française

In a tax news release published on December 18, 2025, Revenu Québec confirmed how it will adapt its voluntary disclosure practices following the CRA's publication on September 10, 2025, of its new Information Circular IC00-1R7 and Memorandum 16-5-1.

This tax update announces that a new Interpretation Bulletin ADM. 4/R9 will be published shortly, which will undoubtedly contain more details on Revenu Québec's new practices, which will apply to all voluntary disclosures application made after December 17, 2025.

Based on the summary contained in the December 18, 2025, tax update, the main elements of Revenu Québec's new practices are as follows:

a) as at the federal level, the concepts of “General Program” and “Limited Program” are being abandoned and replaced by a new approach of “prompted” or “unprompted” applications;

b) the concept of “prompted application” is defined as follows:

“An application is considered prompted when it is made following verbal or written communication about an identified compliance issue related to the disclosure, which may include letters or notices to the person (excluding education letters) that do one or more of the following:

• identify a specific error or omission found in the person's account;
• set a deadline for correcting an error or omission, where Revenu Québec expects the person to file a return or comply with their obligations.

An application is also considered prompted if it is made after Revenu Québec has already received information from third-party sources regarding potential tax non-compliance by the person (or a related person).”

c) the relief offered will vary depending on the type of application;

d) there will be no criminal proceedings in either case, and penalties will be eliminated 100% for unprompted applications, while they may be reduced “up to 100%” for prompted applications;

e) for unprompted applications, interest will be charged for the six calendar years preceding the year in which the disclosure came into effect, but will be reduced by 50% for the years in question that are prescribed;

f) requests, interest will be charged for the ten calendar years preceding the year in which the disclosure takes effect, at 100% for the six most recent years and with a 50% reduction for the more distant years in question.

As expected, the major difference between the new federal program and the changes announced by Revenu Québec is that Revenu Québec continues to require, with respect to applicable taxes, that all omissions for all periods in question be corrected through voluntary disclosure.

It should be noted that, at the federal level, the new policy requires corrections for the following specific number of years, with the CRA having the discretion to require more if necessary:

• four years for GST/HST omissions;
• six years for income tax omissions;
• ten years for foreign income or assets.

It will therefore be necessary to continue to deal with different terms and conditions for the two levels of government in this regard.

Additional details will be provided when the new interpretation bulletin ADM. 4/R9 is published.

This article was written by Paul Ryan and published in the APFF newsletter.