Where an invoice for services rendered bears a valid GST/HS registration number, would failure to file a T4A result in the application of the penalty? CRA responded:
In 2010, the T4A form was amended to add Box 048 "Fees for services--Business income"… . At that time, the CRA had announced a temporary measure specifying that taxpayers would not be penalized for failing to properly fill in Box 048. However, this has never had the effect of relieving taxpayers of their responsibility to report these payments.
Thus, a penalty under subsection 162(7) is applicable for non-filing if payments for services are not reported on the T4A form, even if an invoice with valid tax numbers is provided to the payer.