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December 23, 2025

Letter to industry - Update on Trust Tax Issue

This letter is in reference to the letter published by the Bank of Canada on September 8, 2025, indicating that there may be unintended consequences under the Income Tax Act for Payment Service Providers (PSPs) seeking to comply with the Retail Payment Activities Act (RPAA). Specifically, the September letter noted that there could be tax consequences or administrative burden under the Income Tax Act for PSPs seeking to safeguard end-user funds using the “in trust in a trust account” method while retaining interest income on the end-user funds they hold.
Content Type(s): Press, Announcements Research Topic(s): Retail payments supervision
September 8, 2025

Letter to Industry on Trust Tax Issue

As of September 8, 2025, the Bank of Canada’s mandate to supervise Payment Service Providers (PSPs) under the Retail Payments Activities Act (RPAA) is in effect, including regulatory obligations related to operational risk and end-user funds safeguarding. The Bank and the Department of Finance have been made aware of possible unintended tax consequences for PSPs seeking to comply with the safeguarding requirements of the RPAA using the “in trust in a trust account” method.
Content Type(s): Press, Announcements Research Topic(s): Retail payments supervision
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