CBSA approves the section 74 refund and the Statement of Adjustment shows the duty coming off. A few days later the CARM account balance has moved by exactly that amount, and the GST line has not moved at all. Nothing on the SoAdj explains why, and it is not a processing delay.
Why the GST does not come back with the duty
Memorandum D6-2-3, Refund of Duties, states the exclusion in its opening paragraph, before any of the refund mechanics that follow it:
"GST is excluded from all refunds made under customs legislation. Any reference to duties in the following guidelines should be read to exclude the GST."
CBSA repeats the same exclusion at the point where it actually happens, in the memorandum that governs adjustments to the CAD itself. Memorandum D17-2-1 is direct about what CBSA will and will not do with a GST refund request:
"The CBSA will accept adjustment requests and render decisions for GST refund requests, where GST has been overpaid when accounting for imported commercial goods on a CAD. The CBSA however, will not issue a credit for the GST refund to the importer's account."
CBSA decides the GST question and records that decision. It does not pay it. The refund itself is filed the same way as any other section 74 claim, as an adjustment against the CAD carrying the reason code on the adjustment that states why the duty changed. None of that reaches the GST line, because GST sits under the Excise Tax Act and the Canada Revenue Agency, not the Customs Act and CBSA's own account.
Who can claim it back as an input tax credit
For an importer registered for GST, the tax paid at import is ordinarily recoverable the same way any other GST paid on a business input is recoverable: as an input tax credit on the regular GST/HST return, not through the CBSA account. CRA's policy statement P-125R sets out the general rule.
"Generally, a registrant is entitled to an ITC with respect to tax on the importation of goods that is paid or payable by the registrant, if the registrant imports the goods for consumption, use or supply in the course of its commercial activities."
Two things have to be true at once for that sentence to apply: registered for GST, and the one actually importing the goods for its own commercial activity.
What if the importer of record is not the one who actually imported the goods
That second condition is where CRA's rule stops following the CAD's own paperwork. Entitlement does not turn on who is named as importer of record. CRA's own wording:
"It is only the de facto importer who may be considered to have imported the goods for consumption, use or supply in the course of its commercial activities."
When the importer of record and the de facto importer are two different businesses, CRA puts the paperwork burden on the one entitled to claim, not the one named on the entry:
"The de facto importer will be required to obtain a copy of the import documentation from the importer of record in order to satisfy the documentary requirements for claiming the ITC."
Being named on the CAD is not the test. Being the party that actually imported the goods for its own commercial use is.
How does a non registrant get the GST back
A trader that is not GST registered has no return to put an input tax credit on, so CRA gives it a separate form instead. Memorandum D17-2-1 names it directly:
"TCPs who are non-GST registrants can submit Form GST 189, General Application for Rebate of GST/HST, along with their SoAdj from the CBSA, to the CRA to request their refund."
CRA's current form page lists it as GST189, General Application for GST/HST Rebates. Either way, the SoAdj CBSA issues on the CAD adjustment is evidence attached to that application, not a claim CRA acts on by itself. The non registrant still has to file GST189 and send it in.
Is this a refund or a correction
D6-2-3 also draws the line this page has been assuming throughout. A section 74 refund is something the importer chooses to file, on a four year clock, and it sits apart from the obligation to fix a declaration once it is known to be wrong:
"While corrections to declarations under section 32.2 are obligatory, refunds under section 74 of the Act are voluntary."
That is a different question from the 90 day correction clock that starts once an importer has reason to believe an entry was declared wrong. Everything above only comes up after a section 74 refund has already been filed and CBSA has already decided it. The GST question sits downstream of that decision, and it ends at CRA, not at CBSA.
Was it declared right? That is a line by line question about a document, and it has a definite answer. Norquin checks Canadian customs entries against the published tariff and says plainly which lines it cannot prove.
Sources. Every figure above was read off these pages.
- Memorandum D6-2-3, Refund of Duties. Issued 10 September 2018; paragraph 1 excludes GST from customs refunds, paragraph 2 sets the section 74 four year period and the section 32.2 versus section 74 distinction.
- Memorandum D17-2-1, Adjusting Commercial Accounting Declarations. Ottawa, 21 October 2024; paragraph 34, Refunds of GST.
- CRA GST/HST Policy Statement P-125R, Input Tax Credit Entitlement for Tax on Imported Goods. Issued 1 June 2007; the general rule and the de facto importer test.
- CRA Form GST189, General Application for GST/HST Rebates.
Read on 3 September 2026. CBSA revises these notices without a changelog, so check the date on its page before relying on this one.