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Immigration consultant tax services: where the client sits sets the HST
The same PR application can be zero-rated or carry 13 percent HST depending on whether your client is outside Canada or already here — and IRCC fees you pay as agent are disbursements, not income. We keep the place-of-supply calls, the client-account discipline your College requires, and the T2125 or T2 all pointing the same direction.
By the AnalytIQ Accounting team · Last reviewed: August 12, 2026
Zero-rated or 13 percent: the call you make on every retainer
Consulting services supplied to a non-resident are generally zero-rated — taxable at 0 percent — but the zero-rating is lost when the service is rendered to an individual while that individual is in Canada. For an RCIC practice, that single rule splits the client list in two: the applicant in Delhi or Manila pays no GST/HST on your fee, while the work-permit holder in Brampton applying for permanent residence pays 13 percent. The status is set file by file, and a client who lands partway through an engagement can change the answer for services rendered after arrival, so our bookkeeping tags every retainer with client location from day one.
| Client scenario | GST/HST on your fee |
|---|---|
| Study-permit applicant living abroad | Zero-rated — 0%, and you still claim input tax credits |
| Work-permit holder in Ontario applying for PR | Taxable — 13% HST for an Ontario place of supply |
| Canadian employer retaining you for an LMIA | Taxable — your client is the resident employer, wherever the worker is |
| IRCC fee paid from the client account as agent | No GST/HST — a disbursement passed through at cost, itemized separately |
| Flat package with IRCC fees folded into your fee | The whole amount takes your service's tax status — the government fee stops being a disbursement |
Zero-rated is not exempt, and the difference is money. Zero-rated sales count toward the $30,000 small-supplier threshold and preserve your input tax credits, so a practice serving mostly overseas clients typically collects little HST while recovering the HST it pays on rent, software, and advertising — registration often produces net refunds rather than net remittances.
IRCC fees: agent disbursement or part of your price
Government fees are not subject to GST/HST, and they stay that way on your invoice only if you incur them as agent: paid from client funds, passed through at exact cost, and shown as a separate line. Fold them into a flat package price and they become part of the consideration for your service — taxable at whatever rate your service carries, which quietly overcharges overseas clients nothing but adds 13 percent to the government's own fee for in-Canada clients. We set the invoice template once so every biometric fee, right-of-PR fee, and application charge flows through correctly.
The client account is not income yet
CICC rules require fees received before services are rendered to sit in your client account, and tax law agrees with the spirit: a retainer becomes income as it is earned under the agreement, not when it arrives. We mirror the College's compliance ledger in the books — client-account balances as liabilities, transfers to the operating account recognized as revenue against milestones in the retainer agreement. That alignment means your College reporting, your bank reconciliations, and your tax return tell one story, and year-end revenue reflects work actually delivered rather than cash that may still be refundable.
T2125 or T2, and the deductions that carry the file
A solo RCIC reports on a T2125; incorporation starts to pay once you retain earnings, hire case processors, or build a firm brand worth separating from yourself, with retained profits taxed at Ontario's small-business rate of about 12.2 percent. Either way, the deduction set is distinctive: College registration and E&O coverage, continuing professional development hours, case-management software like Officio, translation and courier costs not billed as disbursements, and marketing aimed at overseas markets. Referral commissions paid to overseas education or recruitment agents are deductible with contracts and proof of services — undocumented wire transfers abroad are a review magnet. Payments in have their own wrinkle: overseas clients pay in US dollars or through remittance platforms, and each receipt converts to Canadian dollars at the rate on the date received, with platform charges booked as a cost rather than netted out of revenue. Family members who handle intake or document collection can be paid for that work when the pay matches the role and actually moves. For clients whose own tax lives straddle the border, and for your practice's US-side questions, see our immigration consultant cross-border tax page; how we price and run engagements is on our tax services page.
Common questions.
Do I charge HST to clients who are outside Canada?
Generally no — consulting services to a non-resident individual outside Canada are zero-rated. Once the client is in Canada while you render the service, the fee becomes taxable at the place-of-supply rate, 13 percent for Ontario.
Are IRCC application fees part of my income?
Not when you pay them as agent from client funds and pass them through at exact cost on a separate invoice line. Bundle them into a flat fee and they become part of your taxable price.
Should I register for GST/HST if most of my clients are abroad?
Usually yes. Zero-rated sales count toward the $30,000 threshold, and registration lets you recover HST paid on rent, software, and advertising — many overseas-focused practices receive net refunds.
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