Respecting whether a s. 162(7) penalty will be imposed for failure to provide a T4A to a service provider even if the provider’s invoice bear a proper GST/HST registration number, CRA indicated that, although in 2010, it had announced a “temporary measure” indicating that it would not penalize taxpayers for failure to complete Box 048 (re fees for services):
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.