In a tax news release published on December 18, 2025, Revenu Qu\u00e9bec 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.<\/p>\n
This tax update announces that a new Interpretation Bulletin ADM. 4\/R9 will be published shortly, which will undoubtedly contain more details on Revenu Qu\u00e9bec’s new practices, which will apply to all voluntary disclosures application made after December 17, 2025.<\/p>\n
Based on the summary contained in the December 18, 2025, tax update, the main elements of Revenu Qu\u00e9bec’s new practices are as follows:<\/p>\n
a) as at the federal level, the concepts of \u201cGeneral Program\u201d and \u201cLimited Program\u201d are being abandoned and replaced by a new approach of \u201cprompted\u201d or \u201cunprompted\u201d applications;<\/p>\n
b) the concept of \u201cprompted application\u201d is defined as follows:<\/p>\n
\u201cAn application is considered\u00a0prompted\u00a0<\/strong>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:<\/p>\n An application is also considered prompted if it is made after Revenu Qu\u00e9bec has already received information from third-party sources regarding potential tax non-compliance by the person (or a related person).\u201d<\/p>\n c) the relief offered will vary depending on the type of application;<\/p>\n d) there will be no criminal proceedings in either case, and penalties will be eliminated 100% for unprompted applications, while they may be reduced \u201cup to 100%\u201d for prompted applications;<\/p>\n 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;<\/p>\n 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.<\/p>\n As expected, the major difference between the new federal program and the changes announced by Revenu Qu\u00e9bec is that Revenu Qu\u00e9bec continues to require, with respect to applicable taxes, that all omissions for all periods in question be corrected through voluntary disclosure.<\/p>\n 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:<\/p>\n\n