Federal Court Blocks CRA’s Bid to Obtain Six Years of Shopify Merchant Data
The ruling sets a precedent by limiting how tax agencies can request extensive data from third-party platforms.
Overview
- Judge Guy Régimbald ruled the CRA’s demand for more than six years of Shopify records was overly broad and lacked a defined group of sellers.
- The CRA sought detailed merchant information—including personal identifiers, bank details and transaction histories—under the Income Tax Act and Excise Tax Act.
- Some of the same information had also been requested by the Australian Tax Office to verify compliance with Australian laws.
- Shopify was awarded CAD 90,000 in legal costs after winning parallel cases over the data demand.
- The CRA has 30 days to appeal the decision, underscoring tensions between tax enforcement and online seller privacy.